The EU has released several key documents on the EU Deforestation Regulation (EUDR), signaling major burden reduction—officials predict that companies' annual compliance costs will drop by 75%.
These updated regulations directly address the previous compliance challenge where enterprises faced uniform obligations regardless of their supply chain role. Under the new framework, compliance requirements are now tiered based on the entity's position and scale within the supply chain, shifting the focus from blanket compliance to targeted supply chain optimization.
This guide breaks down the simplified obligations and applicable measures for each supply chain role under EUDR, including upstream operators, downstream operators, traders, non-EU suppliers, and authorized representatives.
Upstream Operators – The Primary Responsible Party for Compliance
Core Positioning
Any natural or legal person who places EUDR-controlled products on the EU market for the first time or exports them from the EU market, including importers, exporters, and EU local producers.
Explicitly excluded: End consumers (individual buyers) and third-party companies that provide overseas warehousing, shipping, customs clearance and other services. These entities are not required to comply with EUDR.
Compliance Requirements
Complete supply chain due diligence, submit a Due Diligence Statement (DDS) in the information system, obtain a DDS number, and retain relevant records for five years;
Transmit the DDS number to downstream operators and traders;
Large enterprises are required to publicly report annually on their due diligence systems and measures taken to reduce product risks.
Small and Micro-sized Primary Operators – The Primary Responsible Party for Compliance
Core Positioning
Individuals, micro or small enterprises located in low-risk countries that cultivate, harvest, or raise EUDR-controlled products on their own land and then market or export them to the EU are a branch of upstream operators, such as small farmers or small forest farm owners.
Compliance Requirements
Complete supply chain due diligence and submit a one-time simplified declaration in the information system to obtain a declaration identifier;
Transmit declaration identifiers to downstream operators and traders.
Simplification Measures
Geographic information data can be simplified and replaced with postal codes;
The Commission is promoting data interconnection. If local product information is already in the databases of EU member states and has been synchronized to the EUDR system, micro, small and medium-sized enterprises (MSMEs) can directly access the existing data.
Downstream Operators – Compliant Service Providers
Core Positioning
Any natural or legal person, such as a processing plant or product manufacturer, that uses EUDR-controlled products that have undergone due diligence as raw materials for secondary processing and production, and then puts the new products on or exports them from the EU market.
Compliance Requirements
Large enterprises must register in the information system;
Collect and retain DDS number/declaration identifier and supplier-related basic information for five years.
Simplification Measures
Supply chain due diligence and the submission of due diligence statements are no longer required.
Traders – Compliant Circulation Entities
Core Positioning
In addition to upstream/downstream operators, any natural, legal or associational entity that supplies/circulates EUDR-controlled products to the EU market, such as distributors within the EU.
Compliance Requirements
Large enterprises must register in the information system;
Collect and retain DDS number/declaration identifier and supplier-related basic information for five years.
Simplification Measures
Supply chain due diligence and the submission of due diligence statements are no longer required.
Non-EU Suppliers – Core Data Providers
Core Positioning
The entity established in a third country that supplies EUDR-regulated products to companies within the EU is the core provider of EUDR due diligence information.
Compliance Extension Work
Although non-EU suppliers are not directly regulated by regulations, based on the rigid requirements of supply chain traceability, suppliers assume substantial compliance coordination responsibilities and cooperate in providing a full set of supporting materials, including the geographical coordinates of the land plot, evidence of the complete procurement chain, and legal production certificates from the country of origin.
Authorized Representative – Technical Mentor
Core Positioning
Natural or legal persons within the EU who are authorized in writing to assist in completing relevant compliance matters.
It should be clarified that the authorized representative is not subject to EUDR control and does not bear the ultimate responsibility for product compliance; the relevant responsibility still rests with the EU company that entrusted the representative.
Simplification Measures
Individuals or micro-enterprises engaged in production and operation in their own capacity may entrust the next link in their supply chain (non-individuals/micro-scale downstream operators or traders) as “authorized representatives” to submit due diligence statements or simplified statements on their behalf.
In Conclusion
REACH24H Reminder
The "simplification" under EUDR does not lower compliance standards. Instead, it replaces uniform obligations with role- and scale-matched requirements, ensuring that compliance effort is proportional to the entity's position in the supply chain.
For businesses, the key to EUDR compliance is identifying your supply chain role and applying the corresponding requirements—no more, no less.
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