Pontos-chave
- The EU Deforestation Regulation (EUDR — Regulation (EU) 2023/1115) prohibits placing on the EU market or exporting from it any in-scope commodity unless (a) deforestation-free (no land conversion after 31 December 2020), (b) produced in compliance with country-of-production legislation, and (c) covered by a valid Due Diligence Statement (DDS) with geolocation data.
- In-scope commodities are cattle, cocoa, coffee, oil palm, rubber, soya, and wood plus listed derivatives. Many natural-product B2B buyers think this excludes herbs and dried fruit. It does for the named seven only — but adjacent products and shared logistics flows are still affected.
- Operators (first placers on the EU market) carry full due diligence liability. Penalties include fines of at least 4% of EU annual turnover, confiscation, exclusion from public procurement.
- Applicable date is 30 December 2025 for large operators and traders and 30 June 2026 for SMEs — confirmed after a one-year postponement adopted in late 2024. Plan now; the GIS, DDS, and supplier-data infrastructure cannot be built in 30 days.
Introdução
The EU Deforestation Regulation is the most consequential supply-chain compliance shift since REACH. It does not stop at palm oil and timber. Its data infrastructure — geolocation per parcel of land, supplier due diligence, DDS reference numbers travelling the supply chain in EU TRACES NT — sets the operational template for the next wave of EU sustainability law (CSRD Scope 3, CBAM, DPP, Forced Labour Regulation).
O que EUDR realmente exige
Three substantive obligations apply to every in-scope shipment:
- Deforestation-free: produced on land not subject to deforestation after 31 December 2020.
- Legality: production complies with country-of-production legislation — land-use rights, environmental protection, third-party rights, labour rights, FPIC, tax/customs.
- Due Diligence Statement (DDS): filed in TRACES NT before placing on or exporting from EU market, containing geolocation coordinates of every plot and a risk assessment.
DDS reference number then accompanies the shipment downstream.
Mercadorias e derivados no escopo
Annex I covers seven commodities:
| Commodity | Notable derivatives in scope | | --- | --- | | Cattle | Bovine leather, beef, offal, hides | | Cocoa | Beans, butter, paste, powder, chocolate | | Coffee | Green and roasted, coffee extracts | | Oil palm | Palm oil, palm kernel oil, derivatives, glycerol from palm, oleochemicals | | Rubber | Natural rubber, tyres, rubber-derived industrial goods | | Soya | Beans, oil, cake, derivatives | | Wood | Sawn wood, pulp, paper, charcoal, furniture |
A single palm-oil derivative used as carrier in a cosmetic, emulsifier in a snack, or base in an essential-oil dilution can pull an otherwise non-EUDR product into scope.
Por que afeta cadeias de fornecimento de produtos naturais
Herbs, dried fruit, essential oils, most botanical extracts are not on Annex I. But the regulation reaches natural-product B2B procurement through five routes:
Ingredientes derivados de óleo de palma
Many cosmetic-grade emulsifiers, surfactants, glycerin, natural-derived actives originate from palm-oil chemistry. A natural-extract using palm-derived glycerin as solvent brings the palm-oil EUDR obligation along.
Lecitina de soja e emulsionantes
Standard in many private-label snack and confectionery formulations. Triggers EUDR for the soy component.
Produtos acabados contendo cacau
Private-label snack lines that include cocoa, chocolate coatings, or cocoa-butter components are squarely in scope.
Café em categorias de bebidas e HORECA
Coffee-bean and coffee-extract sourcing in scope; downstream products (RTD coffee, coffee-flavoured snacks) derivative-in-scope.
Logística e madeira de embalagem
Wooden pallets and wood-derived packaging are in scope. Many EU importers now require EUDR-compliant pallet declarations from Turkish and all other suppliers as a procurement pre-condition.
For a comprehensive view see the sustainable agriculture and ESG guide.
Quem é o "operador" e quem o "comerciante"?
- Operator — natural or legal person that, in commercial activity, places relevant products on EU market for first time, or exports them. Most commonly the EU importer, but for a Turkish supplier shipping under DDP or acting as importer of record, the supplier becomes the operator.
- Trader — any other person in supply chain making products available on EU market. Lighter compliance burden; SME traders even lighter.
Operators bear full due diligence: data collection, risk assessment, mitigation, DDS submission. Traders must collect and keep DDS reference and supplier identity, provide on request.
O que contém uma Declaração de Diligência
DDS is filed via TRACES NT. Core data:
- Operator identity — name, address, EORI number.
- Commodity / product description — HS code, trade description, scientific name, quantity, supplier identity.
- Country of production — and parts of countries where applicable.
- Geolocation — coordinates of every plot. For plots ≥ 4 hectares, polygon coordinates required; smaller plots, point coordinates suffice. For cattle, all establishments where kept.
- Risk assessment — methodology, conclusion, mitigation.
- Conclusion — explicit declaration of due diligence performed and no or only negligible risk found.
DDS reference number returned by TRACES NT must accompany the customs declaration.
Benchmarking de países: baixo / padrão / alto risco
The Commission publishes a country benchmarking classifying countries (or parts) as low, standard, or high risk. Methodology considers deforestation rate, agricultural expansion, production trends, rule of law.
- Low-risk — operators may rely on simplified due diligence (information collection without full risk assessment and mitigation). DDS still required.
- Standard-risk — full due diligence.
- High-risk — full due diligence + enhanced scrutiny, 9% of operators and shipments subject to compliance checks (vs 3% standard, 1% low).
Benchmarking is dynamic. Confirm current country tier each quarterly DDS planning cycle.
Dados de geolocalização: o que fornecedores devem fornecer
Single biggest practical change. Required:
- Latitude and longitude of every production plot, decimal degrees, WGS84 reference system.
- Polygon vertices for plots ≥ 4 hectares (recommended for all plots).
- Date or time range of production linked to each plot.
- Plot identification consistent with national land registries where possible.
Most natural-product Turkish suppliers source from cooperative networks of small farms — often hundreds of plots per harvest. Suppliers that have invested in a digital traceability platform are ahead.
Questionário de qualificação de fornecedor
A serious supplier qualification questionnaire — to send to every Turkish, Asian, African supplier of in-scope or adjacent product — covers:
- Scope mapping — which SKUs are in EUDR scope, derivative-in-scope, out of scope.
- Geolocation capability — plot-level coordinates per lot? Format? Accuracy?
- Plot polygon data — for parcels ≥ 4 ha, WGS84 polygon coordinates?
- Production date traceability — link from plot to harvest to processing lot to outgoing lot.
- Legal compliance evidence — land-use rights, environmental permits, labour-law, indigenous rights.
- Country tier monitoring — how the supplier tracks benchmarking changes.
- DDS data delivery format — XML, CSV, API, manual?
- Penalty allocation — contractual allocation of regulatory fines if supplier-side data non-compliant.
For private-label projects where the EU brand is operator, supplier-data quality directly determines brand regulatory exposure. See the private-label snacks production guide.
Penalidades e fiscalização
EUDR penalties are deterrent:
- Fines of at least 4% of operator's annual EU turnover for serious infringements.
- Confiscation of relevant products and revenues from non-compliant transactions.
- Temporary exclusion from public procurement and public funding.
- Temporary prohibition from placing relevant products on EU market.
Member states implement penalties nationally; expect heterogeneous enforcement intensity in first 18 months.
Dois cenários breves
Scenario 1 — Cosmetic brand reformulating body lotion. Brand discovers glycerin supplier sources from palm-derived feedstock. Brand is the EU operator and bears full DDS obligation for palm component. Resolution: switch to certified RSPO-segregated palm glycerin with full geolocation, or substitute to non-palm-derived glycerin. Adds 4 weeks; alternative is structural compliance liability.
Scenario 2 — Snack brand with chocolate-coated dried fruit. Cocoa is in scope. Brand requires Turkish co-manufacturer to source cocoa from EUDR-compliant trader providing geolocation and DDS reference per shipment. Dried fruit itself out of scope (apricot, fig). Pallet wood in scope; supplier provides ISPM-15 + EUDR-compliant pallet declaration.
Como fornecedores turcos respondem
Turkish exporters supplying EU retail are investing in:
- Digital traceability platforms linking farm → cooperative → processing facility → export lot.
- GIS infrastructure to record plot polygons during harvest.
- Cocoa, coffee, palm-derivative substitution for buyers stepping out of EUDR scope entirely.
- Pallet declarations standardised in supplier dispatch documents.
For the Arovela product range, dominant categories — dried fruit, herbs, essential oils — are not on the in-scope Annex I list. Where buyer-formulated products incorporate in-scope derivatives, supply infrastructure exists to source EUDR-compliant alternatives. For the related supplier-trust framework see the ISO/HACCP/GMP guide.
Expansão futura de escopo
The Commission has signalled scope expansion in subsequent revisions. Categories under discussion:
- Other forest-risk crops — maize, sugarcane, possibly select tree-nut categories.
- Other ecosystems — savannah and grassland conversion.
- Financial-services scope — banks and insurers' indirect exposure.
A buyer who builds plot-level geolocation, DDS, and supplier-data architecture now is positioned to absorb the next regulatory step at low marginal cost.
FAQ
Are dried apricot, fig, and herbs in EUDR scope? No, not on Annex I. But check derivative ingredients in any formulated product (palm, soy, cocoa derivatives) and the wood pallets used for export.
Difference between simplified and full due diligence? Simplified applies when sourced exclusively from low-risk countries: information collection without full risk-assessment and mitigation. Standard and high-risk countries require full due diligence.
Who pays for geolocation data? Industry practice is converging on supplier providing geolocation as part of lot documentation, with cost embedded in unit price.
What is TRACES NT? EU's online platform for sanitary, phytosanitary, and now EUDR documentation. Operators register, submit DDS filings, receive reference numbers via TRACES NT. Operated by European Commission DG SANTE (with DG ENV for EUDR).
Can a non-EU supplier file a DDS directly? Only if acting as operator (e.g., as exporter of record under DDP — see the Incoterms guide). The first EU operator typically files. Suppliers provide underlying data.
Construir fornecimento pronto para EUDR agora
The regulation is in force. Data infrastructure takes 6–12 months to build, not 30 days. Browse our wholesale and B2B options, see the related supplier migration playbook and sustainable agriculture guide, or request a quote with full traceability documentation.