EUDR regulation - check if it applies to you

Regulation 2023/1115 of the European Parliament and of the Council of May 31, 2023 on the making available on the Union market and export from the Union of certain goods and products related to deforestation and forest degradation and repealing Regulation (EU) No. 995/2010 regulates the obligations related to the marketing, making available and export of certain products.

The regulation aims to restrict the marketing of certain goods whose production is linked to deforestation and forest degradation. It also seeks to reduce greenhouse gas emissions and prevent the loss of biodiversity. It is estimated that the main cause of deforestation is the expansion of agricultural land associated with the production of commodities such as cattle, timber, cocoa, soybeans, palm oil, coffee, rubber and some derived products such as leather, chocolate, tires or furniture.

The regulation introduces new requirements for traders. Regulated entities are any natural or legal person who, in the course of commercial activities, places the relevant products on the market or exports them.

On September 23, 2025, the Environment Commissioner announced that the TRACES NT information system, intended to be the main control tool, will not be able to handle the influx of data from economic operators as of January 1, 2026. At the same time, she did not give a new effective date for the regulation. However, the lack of substantive changes and only technical problems indicate that the postponement is unlikely to be very long. The Commission’s decision must be approved by the European Parliament.

Regulated companies will have to follow procedures:

• Due diligence, which includes collecting detailed product information;
• risk assessment, whether the products do not comply with the requirements of the regulation;
• mitigating risks, such as by requiring additional information, data or documents, or conducting independent studies or audits.

Once they have fulfilled their obligations, operators, traders and their representatives will submit an electronic due diligence statement to the relevant authorities via the information system to demonstrate that their products do not cause deforestation, according to the Deforestation Regulation. For this purpose, they will use the EUDR system, a registry of due diligence statements, under the European TRACES system.

Entities shall not market or export the relevant products unless they have previously submitted a due diligence statement.

The goods covered by the regulation are:

• cattle,
• cocoa,
• coffee,
• oil palm,
• soybeans,
• rubber,
• wood.

Relevant products means the products listed in Annex I to the Regulation, which contain the above goods, have been fed with them or have been produced using them. The list contains about 70 relevant products, described according to the codes of the Combined Nomenclature For example, a relevant bovine product can be live cattle, various kinds of meat, hides. The relevant product from cocoa is either beans or oil, but also chocolate. The most numerous is the list of wood products, which includes not only various lumber products, but also furniture, picture frames, books and newspapers, while rubber is the tire industry and other rubber products. Palm oil is an ingredient in many food products and cosmetics.

Relevant goods and products may not be marketed, made available on or exported from the market unless they meet all of the following conditions:

• do not cause deforestation,
• have been manufactured in accordance with the relevant regulations of the country of manufacture,
• A due diligence statement was submitted in their case.

The biggest challenge in implementing the Anti-Deforestation Regulation is the scale and complexity of the measures required of businesses. The regulation forces full transparency of the supply chain – including geolocation of the parcels of land from which the raw materials come. This means obtaining detailed data from multiple, often foreign partners.

Knowledge of how to effectively implement the required procedures is very limited. It is difficult to count on the support of government bodies when it is not yet clear which institution will be responsible for enforcing the new regulations. Limited human, organizational and technological resources are an additional difficulty.

Nevertheless, with the implementation of the requirements of the EUDR regulation in the organization is not worth waiting. The consequences of delay can be loss of access to the EU market and severe financial sanctions (the fine can amount to 4% of annual turnover across the EU). Entrepreneurs who fail to comply also risk confiscation of relevant products or revenues, as well as temporary exclusion from tenders, among other things. Specific penalties will be determined by national legislation.

The European Commission has pledged to publish a classification of countries into groups with zero, low, standard and high risk of deforestation (this was to be done by the end of June 2025). Despite the lack of classification, holding companies back is not the best option. Regardless of which group of countries goods will come from, it is still necessary to document the products’ compliance with the new regulations (provide product identification data, proof of compliance with local laws and evidence of no link to deforestation).

Companies that start preparations only after the classification is announced may not make it in time, as it is a very involved process.

The SAP system provides Batch Traceability as standard, so companies can track material flows from raw material to finished product. On the other hand, due to the EUDR directive, it is necessary to link batches of materials at any stage of the company’s processes (from purchase to sale) with documents related to the EUDR directive, the so-called Due Diligence Statements. In order to achieve this goal, dedicated solutions are needed to ensure compliance with the EUDR Directive, to support storage of the required documents, to enable auditing, to support communication with the EUDR platform, one of the instances of the European TRACES (Trade Control and Expert System).

SAP Green Token is an SAP tool that supports the management and accounting of sustainable raw materials in supply chains. It enables you to track and account for certified sustainable and conventional materials according to recognized sustainability standards and regulations, including EURD. SAP Green Token features:

• Material Flow Management: Track the flow of materials and their sustainability attributes throughout the inbound, conversion and outbound processes.
• Compliance with regulations and standards: Support for standards and regulations such as ISCC, EUDR and CBAM.
• Auditable: Auditable, unassailable records, enabling comprehensive monitoring.

The solution is available in a SaaS model. With its open APIs for automation and integration, it can be easily integrated with your ERP system (including ECC, S/4HANA).

The product enables companies to prove that they are using certified materials. It provides transparency in the supply chain, helping to increase partner trust. By helping to meet regulatory requirements and standards related to sustainability, it helps reduce the risks associated with the fraudulent use of sustainable materials.

All for One Poland supports companies in implementing this solution.

Regarding the implementation of the EUDR regulation in SAP, at All for One we are also working on our own solution, an add-on to SAP ECC 6.0 and SAP S/4HANA (on-premise and private cloud).

Our package consists of the following functional elements:

• Configuration transaction – determination of the types of processes (based on the types of material movements/supplies) relevant to the regulation;
• Transactions to manage master data – assignments of HS codes for materials (Harmonized Commodity Description and Coding System), management of locations (storage of GeoJSON files);
• DDS document register – management of preparation and dispatch of DDS statements, document review, status report;
• EUDR Hub – a communication platform that acts as an intermediary in the exchange of data between the client system and the EUDR platform within the European TRACES system.

The process supported by our solution begins with the acquisition of goods classified on the basis of HS codes as relevant to the EUDR. In the SAP system, the source document will be material receipt or inbound delivery. The DDS statement will be automatically completed with the information available in the system (supplier, material, quantity). Before shipping, the missing information must be completed manually (e.g. GeoJSON file if the plantation location is not yet in the system).

The complete document will be sent to the EUDR system via the EUDR Hub. The obtained reference number will be stored in the system and placed automatically in the dedicated material batch attribute. One of the solution’s features is automatic batch status management, i.e., setting a limited-use status for materials requiring a DDS statement to be sent until a reference number is obtained for the statement sent.

Another process related to the obligation to send a DDS statement is the processing of materials (consumption of raw materials and acceptance of the finished product). The need then arises to send statements for raw materials consumed in order to obtain a new reference number for the finished product. This step will be performed automatically, based on the declarations already in the system.

The final stage is the sale of materials subject to EUDR (both finished goods and trade goods). Our solution will support sending DDS documents in electronic form (e.g. as XML).

Interested companies are encouraged to contact us for an analysis of the scope of changes necessary to be made both in your system and possible adaptations of our solution to the specifics of your processes.