EU Deforestation Regulation update: It’s now time to act, not wait

For food and beverage supply-chain leaders, the latest shifts in the EUDR rule-set signal both opportunity and risk. At Mondra, we believe your readiness for the new regime will define whether the regulation becomes a cost burden or a competitive advantage.

The EUDR Challenge

• The EUDR is designed to ensure commodities and derived products placed on the EU market (e.g. coffee, cocoa, palm oil, soy, rubber, cattle, wood) are deforestation-free and legal under the law of origin.

• Implementation has been delayed, revised and simplified multiple times due to concerns about the IT system, supply-chain burdens, and regulatory readiness.

• For large and medium operators the 30th December 2025 deadline remains in place but a six-month “grace period” for enforcement has been proposed.

• For small enterprises, a new application date of 30th December 2026 has been proposed.

• Under the modified EUDR, the responsibility (e.g. traceability / geolocation, and supply-chain monitoring) to submit a Due Diligence Statement (DDS) to the EU's TRACES IT system will primarily fall on the 'upstream operator, i.e. the operator that imports the product into EU, however downstream actors (manufacturers, traders and retailers) may see their burdens reduced under recent proposals, which would remove their need to file a separate DDS. They will however still be required to obtain and retain the DDS reference number from the upstream operator.

• The regulatory environment remains fluid. Simplifications equate regulatory risk for those who have invested early, and potential compliance cost for late movers. Some stakeholders have voiced concerns that watering-down of obligations undermines the original intent of the law.

Why you should care

For your role as a Sustainability Lead / Procurement or Supply-Chain Director in the food & beverage sector:

• The EUDR touches your Scope 3 emissions, your supplier data burden, your audit-readiness, and your ability to demonstrate “deforestation-free” sourcing to European regulators and customers.

• If your organisation utilises multi-tier supply chains (common in F&B), non-compliance may trigger regulatory scrutiny, supply capture risk, and reputational damage.

• Because the timing, enforcement and registration mechanisms are now clearer, your decision-window is closing. The final deadlines are now imminent, haste will now be the imperative. Preparing early gives you a strategic edge while waiting increases cost and risk.

• The proposed simplifications for downstream operators mean that if you act now, you may benefit more than those who delay. This means you may be able to leverage reduced obligations while securing better supplier positions and cleaner traceability.

photo courtesy of: https://unsplash.com/@justusmenke

How can the Mondra platform support you?

Mondra’s solutions align with the emerging EUDR-driven requirements:

• Supply Chain Digital Twinning: Enables you to model multi-tier flows, trace commodities from origin to EU market, overlay deforestation-risk maps and compliance flags.

• Sherpa: Carbon Co-Pilot: Helps integrate deforestation-risk into your broader carbon-footprint modelling and Scope 3 pathways (since deforestation links to forest-carbon emissions).

• Our Solution Modules (Net Zero / Compliance / Resilience) by consolidating your data onto Mondra’s product-level Digital Supply Chain Twins:
  
  

  • Compliance - you can embed the specific EUDR requirements (due-diligence statements, geolocation data, upstream operator registration).

  • Resilience - you can assess supplier risk arising from deforestation legislation (e.g., if a key supplier is in a high-risk country, or lacks traceability).

  • Net Zero - you capture the carbon-benefit side of deforestation-free sourcing (forest conservation as carbon mitigation).

Mondra works with an expanding network of trusted partners who specialise in EUDR compliance solutions. These include providers such as Impact Buying, Foods Connected and Trace One who integrate Mondra data into frontline compliance workflows to streamline supplier engagement and accelerate due-diligence checks. This ecosystem approach ensures you avoid fragmented tools and gain support across both supplier traceability and data validation needs.

What does this mean to you?

• Reduced regulatory risk through built-in traceability and audit-ready supply-chain insights.

• Lower cost of compliance via automation of supplier screening, data-collection, geolocation, due-diligence workflows.

• Competitive advantage, if you prepare ahead of peers, you can showcase cleaner supply chains to retailers and customers and embed sustainability into your brand value.

• Future-proofing, as the EUDR regime evolves (and may broaden further), you have the systems in place rather than scrambling to retrofit.

What you should do next

1. Map your in-scope commodity exposure: Identify which of your sourced commodities/products fall under EUDR scope (coffee, cocoa, palm, soy, rubber, cattle, wood and derived products).

2. Classify suppliers by risk: Use country benchmarking (low/standard/high risk) as per EUDR; flag suppliers in “standard/high risk” zones.

3. Ensure upstream-operator registration: If you place in-scope commodities on the EU market, you are responsible for the due diligence statement and compliance checks. If an upstream partner already holds this responsibility, ensure you reference their registration and documentation in your records.

4. Adapt downstream obligations: Monitor the outcome of the simplification rules. Downstream actors may no longer need to submit separate DDS but will still need to retain traceability and supplier reference numbers.

5. Embed data workflows: Collect geolocation of origins, harvest dates, supplier-legal compliance, deforestation-free confirmation. Integrate into your LCA, Scope 3 and risk systems.

6. Use systems for monitoring and reporting: Ensure your audit trails, traceability logs and compliance dashboards are ready ahead of 30th December 2025 (for large/medium firms). If you are a small / micro-operator, then comply with all regulations within 30th December 2026 timeframe.

7. Engage suppliers & build capability: Especially if your supply chain includes large/ medium holders or suppliers in high-risk countries - build training, support and verification frameworks to avoid being a bottleneck.

8. Position your strategy externally: Use your deforestation-free sourcing story as part of your sustainability narrative to customers, investors and regulators. Turn compliance into a brand differentiator.

It’s finally time to act

If your organisation is in scope of the EUDR (and based on your size, geography and commodity exposure you likely are), now is the time to conduct a gap-analysis and build your roadmap.

Mondra can help you align your supply-chain traceability, deforestation-risk modelling, carbon impacts and compliance workflows in one integrated platform. Let’s assess your readiness and turn regulatory burden into strategic value.

When it comes down to capturing that key data from your supply chain, we can recommend some of our incredible partners. Their solutions paired with Mondra's Digital Twins ensures streamlined setup and maximum efficiency. With all captured data able to be mirrored and stored on your Digital Twin to multiply the value over all your Compliance, Resilience and Net Zero pillars.