How Scientific Verification Supports EUDR Compliance

Updated 20 November 2024

The EU Deforestation Regulation comes into effect from the end of 2025. Operators and traders in the industries of coffee, cattle, cocoa, wood, rubber, palm and soy have until then to ensure their products comply with the legislation, or risk significant penalties.

In response to calls from certain sectors citing insufficient time and high costs associated with compliance, the EU Commission has agreed to postpone application of the regulation. It will now come into effect from 31 December 2025 for large companies and 30 June 2026 for small companies.

From this time, only products from land that hasn’t been degraded or deforested after December 31st, 2020, will be permitted for import into or exported from the EU market.

The legislation mandates a process of due diligence for all businesses in affected industries. Scientific traceability provides an important tool to enable and demonstrate compliance.

Origin is a cornerstone of due diligence

Due diligence statements are a critical part of the activities that businesses must undertake to determine that their products are deforestation-free.

These statements must include the country of production for their commodities and geodata coordinates of the plots they originate from, as well as a risk assessment evaluation.

The regulation states that companies must demonstrate “that the absence of deforestation and forest degradation and legality requirements are fulfilled, by identifying the country of production or parts thereof and including the geolocation coordinates of relevant plots of land.”

Businesses must therefore collect information to support the claims made in their statements, before submitting these through the public information system.

Since enforcement authorities will be checking the due diligence statements submitted, it’s essential that companies ensure the information they provide is accurate to avoid penalties. If the information is inaccurate or insufficient, and businesses thus cannot prove where their products originate from, they cannot prove compliance – and thus potentially lose the ability to import.

For ensuring EUDR compliance, it’s imperative that businesses can prove the origin of their products.

Untangling complex supply chains

Meeting these requirements becomes more challenging when the origin of the product is unknown, or where companies are dealing with very complex supply chains with multiple actors involved. This could include situations involving commodities like coffee, palm or cocoa that are often mixed or blended, and where the risk of these being blended with commodities originating from risk area is higher and definitively proving the origin is difficult.

To achieve EUDR compliance, especially in cases like these, it’s essential to accurately map supply chains to gather information and ensure that the information provided by suppliers and other partners is correct.

The key to this is accuracy – relying on vendor self-declarations or paper trails alone is unlikely to be enough.

Indeed, the EUDR specifically focuses on “document and data falsification” in the verification of origin, particularly where such fraud is being carried out deliberately to circumvent the legislation.

Many companies will have little visibility over their broader supply chains, and when they know they may be sourcing from high-risk areas (that is, countries with deforested areas), a reliable, accurate solution for product traceability will be essential.

Scientific solutions for scientific objectives

The importance of scientific evidence is a common thread running throughout the wording of the EUDR. For example:

• Assessments of forest degradation must be “based on the most up-to-date scientific data” and “in consultation with the scientific community”.
• The classification of risk levels for countries will be made “taking into account the latest scientific evidence”.
• One of the objectives of the regulation is to promote “sustainable forest management… based on science-based indicators”.

Therefore, employing science-based tools as part of a company’s risk assessment and risk mitigation efforts demonstrates strong alignment with the spirit and provisions of the legislation.

Enforcement authorities will be using several tools, including chemical analyses, as part of their checking of submitted due diligence statements.

The regulation states that checks may include “any technical and scientific means adequate to determine the species or the exact place where the relevant commodity or relevant product was produced, including anatomical, chemical or DNA analysis.”

Using similar techniques to prove country of origin will put businesses in a position of advantage as they will be able to demonstrate compliance to authorities if their operations are brought into question.

Compliance through scientific verification

Forensic origin verification is an established, trusted method of substantiating product origin information.

Oritain’s innovative forensic science tests products and raw materials to verify their origin – a key requirement of EUDR due diligence requirements. Commodities falling under the scope of the EUDR can be audited in this way.

By analysing samples of the products, Oritain can audit at different stages of the supply chain and at different resolutions, to enable companies to verify the information that the EUDR requires for compliance.

The scientific precision of these tests mitigates the risk for companies that believe they’re procuring an EUDR-compliant commodity, only to discover it’s sourced from a deforested area.

The science is also less susceptible to the fraud or inaccuracy found in conventional traceability systems, where the value of the due diligence statements produced are only as good as the information entered into them.

Oritain’s scientific solution aligns to EUDR requirements and provides reliable protection for businesses operating in the EU. In helping ensure they comply with the legislation, it also supports:

• Avoiding noncompliance penalties, product seizures and restrictions of trade
• Improving oversight of and relationships with supply chain partners
• Strengthening business reputation among regulators, investors and consumers

With implementation of the EUDR imminent, it’s contingent on companies to protect themselves with the most reliable solution available.