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The EU Deforestation Regulation (EUDR) applies to large and medium-sized companies from 30 December 2026 and to micro and small enterprises from 30 June 2027. For food manufacturers processing cocoa, coffee, palm oil, soy or beef, every relevant batch must be traceable to a due diligence statement (DDS) and its reference number. The most efficient way to achieve this is to capture EUDR data in the ERP system, right at goods receipt and on the batch record.
After two postponements and a simplification package, the timeline is now settled. Many obligations have become leaner, yet EUDR compliance remains above all a data challenge, and that data belongs where raw materials, suppliers and batches are already managed.
What is the EUDR?
Regulation (EU) 2023/1115 allows certain commodities and derived products to be placed on the EU market, made available or exported only if they are:
- deforestation-free: produced on land that has seen no deforestation after 31 December 2020,
- legal: produced in line with the relevant laws of the country of production,
- covered by a due diligence statement submitted to the EU information system.
The regulation covers cattle, cocoa, coffee, oil palm, rubber, soy and wood, together with the derived products listed in Annex I, such as chocolate, roasted coffee, palm oil and soybean meal.
Which deadlines now apply?
Amending Regulation (EU) 2025/2650 of December 2025 postponed application by one year and simplified the rules. According to Germany's Federal Office for Agriculture and Food (BLE), the timeline is:
| Date | Who is covered |
|---|---|
| 30 December 2026 | Large and medium-sized operators and traders, plus micro and small enterprises in the timber sector |
| 30 June 2027 | All other micro and small enterprises |
With its review package of 4 May 2026, the European Commission confirmed that the legal text will not be reopened. On 13 July 2026, two final acts followed: a delegated regulation updating the product list in Annex I and Implementing Regulation (EU) 2026/1565 on the EU information system. Check your items against the current version of Annex I. The timeline is set.
What did the simplification change for food businesses?
The key changes, as summarised by the BLE and AEB:
- The first placer files the DDS: the company that first places a commodity on the EU market, usually the importer, submits the due diligence statement.
- The first downstream operator keeps reference numbers: later stages in the supply chain are released from this duty.
- Simplified declaration for small primary producers: micro and small primary producers submit a one-off simplified declaration.
- Practical system features: Implementing Regulation (EU) 2026/1565 of 13 July 2026 makes submitting statements easier, allows information to be bundled and defines fallback procedures for system outages.
In practice, a chocolate maker importing cocoa liquor directly from West Africa carries the full due diligence obligation. A bakery buying couverture from an EU wholesaler has a far lighter task. The first step for every company is therefore to clarify its role for each raw material.
What data does a food manufacturer need?
Due diligence follows three steps: collect information, assess risk, mitigate risk. The core data set includes:
- product description, quantity and HS code
- country of production and geolocation of the plots, with polygons for plots larger than four hectares
- suppliers and customers of the goods
- evidence that the goods are deforestation-free and legally produced
- the DDS reference number, to be retained for five years
The EU country benchmarking of May 2025 makes risk assessment easier: most countries are classified as low risk, while Belarus, Myanmar, North Korea and Russia are rated high risk. Goods from low-risk countries qualify for simplified due diligence.
How can an ERP system support EUDR compliance?
The EUDR builds on exactly the data a food ERP already holds for batch traceability. Five building blocks turn it into a robust compliance process:
- EUDR flags in the item master: HS code, EUDR relevance and commodity assignment for each raw material, so every relevant goods receipt is identified automatically.
- Supplier master with role and evidence: whether a supplier is the first placer, which geodata and certificates are on file, and when they expire.
- Reference number at goods receipt: the DDS reference is captured together with the supplier batch, ideally extracted automatically from the delivery note or EDI message.
- Inheritance through recipes: production batches show which EUDR references are contained in which finished product, including mass balance for mixed batches.
- Validation rules and reporting: only batches with a complete reference are released for production, and evidence for authorities is available at the push of a button.
With the fabular platform, these fields, rules and workflows can be configured into existing processes without custom code. fabAI takes over the routine work: the AI reads delivery notes, certificates and supplier declarations, assigns reference numbers to the right batches and flags gaps early.
What is a realistic plan until the deadline?
- Right away: screen raw materials, flag EUDR-relevant items and HS codes, clarify your role per commodity.
- Within the next two weeks: contact suppliers, request reference numbers and geodata, store evidence centrally.
- By mid-December: make the reference number a mandatory field at goods receipt and test validation rules.
- From January 2027: run a mock trace with EUDR data and add EUDR data quality to supplier evaluation.
Organic producers have a head start: much of the evidence required for organic certification is already structured and can simply be extended with EUDR fields.
Conclusion
The simplifications have noticeably reduced the effort for many food businesses. At the same time, linking raw material, reference number and batch becomes a prerequisite for market access from 30 December 2026. Companies that bring this data together in their ERP gain legal certainty, faster audits and a strong argument with retail customers.
Want to see how EUDR data fits into your batch and supplier processes? Book a free consultation with our food industry team.
Frequently asked questions
When does the EUDR apply to food manufacturers?
From 30 December 2026 for large and medium-sized companies and from 30 June 2027 for micro and small enterprises.
Who submits the due diligence statement?
Since the 2025 amendment, the operator placing a product on the EU market for the first time submits the statement. The first downstream operator collects the reference numbers; later stages are exempt.
Which food commodities are covered?
Cocoa, coffee, palm oil, soy and cattle, plus derived products listed in Annex I such as chocolate, roasted coffee and soybean meal. Wood and rubber are also covered.
What penalties does the EUDR provide for?
Member states must set fines with a maximum of at least four percent of the company's total annual EU turnover, alongside confiscation of goods and exclusion from public procurement.
Can an ERP generate EUDR evidence automatically?
An ERP links reference numbers, suppliers and batches and thus provides the data foundation. The statement itself is filed in the EU information system, ideally fed directly from ERP data.
