Updated EUDR Guidance: Here’s what you need to know (Apr2025)

Executive Summary

The EU has issued new guidance to help companies simplify EUDR implementation. The updated guidance has no impact on companies that have already gone live with EU TRACES for EUDR compliance, and offers slight efficiencies for companies tackling implementation today. The biggest change to implementation is that an aggregate Due Diligence Statement may now be submitted proactively for up to 1 year of future transactions and the same reference number cited for every shipment it accounts for, provided the volumes of goods are accurately accounted for. This could reduce the frequency of geo-data collection and analysis and favor a pre-screening approach, but only in the event that suppliers have already identified raw material origins. Companies still need to maintain a database of shipment-level traceability tied to originating farms and forests, and to reconcile all volumes so as to avoid an audit. The guidance reiterates a number of established processes, including the fact that legality due diligence only needs to be performed on the raw material suppliers and not intermediaries, that downstream transactions do not require re-submission of geo-data, that EU TRACES will allow companies to share detailed DDS data with their customers, and that no DDS is required for re-sale.

What are the EUDR guidance and FAQs?

On April 15th, the EU Commission published updated guidance and FAQs on the forthcoming EU Deforestation Regulation, set to enter into force on December 30th, 2025. The updated guidance demonstrates an effort by the EU to simplify compliance and reporting obligations for companies. While the guidance and FAQs are not legally binding, they are intended to be used as reference materials for operators and traders who must comply with the EUDR, as they further clarify dedicated parts of the legislative text. These documents do not replace, add to or amend the provisions of the EUDR and should not be considered in isolation; they must be used in conjunction with the legislation and not as a ‘stand-alone’ reference.These guidance documents may also be used as a guide for competent authorities and enforcement bodies within the EU member states, as well as national courts in the process of implementing and enforcing the EUDR.

Due Diligence Statements may be submitted up to one year in advance for goods not yet on the market.

The most notable change from this updated guidance is the inclusion of the option for operators to submit Due Diligence Statements (DDS) up to one year in advance of products being placed on the market. The quantities of the products declared in the due diligence statement must correspond to the quantities that have been subject to due diligence by the operator and are intended to be placed or made available on the EU market or exported. A discrepancy in those quantities may trigger an audit by the competent authorities, and ultimately lead to fines for non-compliance should inaccurate or deceptive record-keeping be identified. Once the quantity of products covered by the due diligence statement has been fully placed on the market or exported, a new statement must be filed for additional quantities by the same operator.

It's unclear how this will help to streamline operations for smallholder crops such as cocoa, coffee, rubber and palm, since the EU TRACES system limits each DDS to 25MB of data, or approximately 10,000 farms. The following is an excerpt from the EUDR FAQs, updated on April 15th.

“ A single DDS can contain a maximum of 200 lines of relevant products. In each line of relevant product has the following maximum allowed limitations are defined 500 lines to record the pairs of Scientific Name(s) / Common Name(s), and 1,000 lines to record the ‘Production place’, which also contain all geolocation coordinates related to the plots of lands where the relevant product was produced in the relevant country of production. As an additional rule, a single DDS can contain 10,000 ‘Production Place’ in total.

Companies importing large volumes will still need to submit multiple DDS to account for all of the farms used in a year of purchasing.”

Operators may still elect to submit a DDS for each shipment, as this is still acceptable under the law. This would be advisable in the case that suppliers do not have sourcing information before the year begins, and may more closely align with other customs documentation and clearance processes.

Clarification on legality requirements: Companies do not need to evaluate intermediate suppliers, only the legal status of the area of production

The updated guidance and FAQs include additional clarification on legality due diligence requirements under EUDR, including how operators should determine whether a law in the country of production is or is not applicable. First, the Commission makes clear importers are not required to evaluate the legality practices of intermediate suppliers, but only of the plots of land that supply raw materials.

The EUDR takes a flexible approach by listing a number of areas of law without specifying particular laws, as these differ from country to country and may be subject to amendments. However, only the applicable laws concerning the legal status of the area of production constitute relevant legislation pursuant to Article 2(40) of the EUDR. Companies are still required to collect documents relating to the right to use plots of land for raw material production, but only those documents required by law in each country to substantiate these rights (for example, some companies only require a business license whereas others may require a land title).

Confirmation that composite products and downstream transactions do not require additional geo-data submission

Many operators place composite products - i.e. derived products made using commodities already placed on the market, referencing more than one Due Diligence Reference Number (DDR) - on the market. The updated guidance clarifies that in this scenario, information contained in existing due diligence statements may be referred to in order to complete the information to be contained in a Due Diligence Statement.

Reference can be made in the EU TRACES system by entering the reference number (DDR) and verification number of an upstream due diligence statement when a new statement is submitted.

Sharing geo-data with customers via TRACES

Operators and traders submitting due diligence statements will be able to decide whether the geolocation information contained in their statements submitted in the Information System will be accessible and visible for downstream operators via the referenced due diligence statements inside the Information System. TRACES will be equipped with security measures that will ensure the integrity and confidentiality of the information that the Information System contains.

No DDS required for re-sale

Finally, products that have already been imported into the EU accompanied by a compliant DDS that are then re-sold domestically or exported without further manufacturing or product transformation will not need to submit an additional DDS prior to said sale or export.

Updates to EUDR Workflows

The updated guidance has no impact on Sourcemap customers that have gone live with EU TRACES for EUDR, nor does it alter legality workflows that have already launched. Some companies launching EUDR workflows today may benefit from a pre-screening approach combined with batch-level traceability to submit aggregate DDS statements. Companies with direct sourcing relationships may also streamline legality, but only in rare cases. To find out more about how Sourcemap's workflows are continuously updated to offer the only automated, fully cloud-based EUDR solution that is live with EU TRACES, and to speak with our team of policy experts, reach out today.