{"id":26707,"date":"2026-10-03T09:00:00","date_gmt":"2026-10-03T09:00:00","guid":{"rendered":"https:\/\/evaluationshub.com\/?p=26707"},"modified":"2026-09-29T15:41:50","modified_gmt":"2026-09-29T15:41:50","slug":"eudr-30-december-2026-supplier-data-plan","status":"publish","type":"post","link":"https:\/\/evaluationshub.com\/eudr-30-december-2026-supplier-data-plan\/","title":{"rendered":"EUDR Applies on 30 December 2026: A 14-Week Supplier Data Plan","gt_translate_keys":[{"key":"rendered","format":"text"}]},"content":{"rendered":"\n<p class=\"wp-block-paragraph\">Just under 100 days separate us from 30 December 2026, the date the EU Deforestation Regulation starts to apply to large and medium operators and traders. Micro and small operators that are new to the rules have until 30 June 2027, although those already covered by the old EU Timber Regulation are in the December group.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">After two postponements, this date looks firm. In its simplification review of May 2026 the European Commission confirmed that the regulation will not be reopened and that the existing timelines continue to apply. The July 2026 package then delivered the practical pieces teams had been waiting for: an updated product scope, a working information system, and guidance and FAQs in all EU languages.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">Here is the encouraging part. Most of what EUDR asks for is supplier data, and collecting supplier data at scale is something procurement teams already know how to do. The teams that will be comfortable in December are not the ones with the best legal memo. They are the ones who started the data campaign early and kept the response rate high.<\/p>\n\n\n\n<h2 class=\"wp-block-heading\">The short version<\/h2>\n\n\n\n<ul class=\"wp-block-list\">\n\n<li><strong>30 December 2026<\/strong> is the application date for large and medium operators and traders, plus micro and small operators previously covered by the EU Timber Regulation. <strong>30 June 2027<\/strong> applies to other micro and small operators.<\/li>\n\n\n<li><strong>Seven commodities are in scope<\/strong>: cattle, cocoa, coffee, oil palm, rubber, soya and wood, along with many derived products such as leather, chocolate, tyres, furniture and paper.<\/li>\n\n\n<li><strong>The core deliverable is a due diligence statement (DDS)<\/strong> submitted through the EU information system, which returns a reference number that travels down the chain.<\/li>\n\n\n<li><strong>Geolocation is the hard part.<\/strong> You need coordinates for every plot of land where the commodity was produced, plus evidence that production was legal in the country of origin.<\/li>\n\n\n<li><strong>Records are kept for five years<\/strong>, so this is a permanent data set, not a one-off filing.<\/li>\n\n\n<li><strong>Several simplifications genuinely reduce the workload<\/strong>, including one statement covering multiple shipments in defined cases, reuse of upstream reference numbers by downstream operators, and a group authorised representative.<\/li>\n\n\n<li><strong>Penalties are meaningful<\/strong>, with maximum fines of at least 4 percent of total annual EU-wide turnover, so this is worth doing properly.<\/li>\n\n<\/ul>\n\n\n\n<h2 class=\"wp-block-heading\">What actually decides whether you are ready<\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">Almost every EUDR article focuses on the legal obligations. That framing is useful for the general counsel and much less useful for the person who has to make it happen.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">In practice, readiness comes down to one number: the share of your in-scope suppliers who have returned complete, usable data. A legal analysis can be finished in a week. Getting plot coordinates out of several hundred suppliers across multiple countries and languages takes months, because it depends on people outside your organisation finding time to answer you.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">That reframing changes what you do first. Instead of starting with the regulation, start with the list of suppliers you need to hear from, and treat the next 14 weeks as a structured data campaign with owners, reminders and a visible completion rate. This is the same discipline as a good <a href=\"https:\/\/evaluationshub.com\/supplier-onboarding\/\">supplier onboarding<\/a> programme, applied to a narrower question.<\/p>\n\n\n\n<h2 class=\"wp-block-heading\">The data you need from suppliers<\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">The regulation is specific about the information an operator has to collect and keep. For each in-scope product, that means:<\/p>\n\n\n\n<ol class=\"wp-block-list\">\n\n<li><strong>Product description<\/strong>, including HS code, trade name and the commodities it contains.<\/li>\n\n\n<li><strong>Quantity<\/strong>, expressed in net mass and, where relevant, volume or number of units.<\/li>\n\n\n<li><strong>Country of production<\/strong>, and for some chains the specific region.<\/li>\n\n\n<li><strong>Geolocation of every plot of land<\/strong> where the commodity was produced. For cattle, this extends to every establishment where the animals were kept from birth to slaughter.<\/li>\n\n\n<li><strong>Evidence of legal production<\/strong> under the laws of the country of origin, covering land use rights, environmental and forest rules, labour rights and tax and customs obligations.<\/li>\n\n\n<li><strong>Supplier and customer details<\/strong> for products that already carry due diligence, including the reference numbers of the statements attached to them.<\/li>\n\n<\/ol>\n\n\n\n<p class=\"wp-block-paragraph\">Two practical notes make this much easier to run. First, composite products need geolocation for each in-scope commodity they contain, so a chocolate bar with cocoa and palm oil generates two data trails rather than one. Second, the five-year retention requirement means this belongs in your permanent <a href=\"https:\/\/evaluationshub.com\/supplier-master-data-governance\/\">supplier master data<\/a>, not in an inbox folder.<\/p>\n\n\n\n<h2 class=\"wp-block-heading\">Where the simplifications genuinely help<\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">The December 2025 revision and the 2026 packages removed real work. Four changes are worth building your plan around.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\"><strong>One statement can cover several shipments.<\/strong> Where the material comes from the same assessed harvest events and nothing in the supply chain has changed, a single due diligence statement can cover multiple shipments within a year. That turns a per-consignment task into a per-supply-chain task, which is a very different workload.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\"><strong>Downstream operators reuse reference numbers.<\/strong> Companies handling products for which due diligence has already been done collect and retain the upstream reference numbers rather than repeating the exercise. First-level downstream operators are not required to chase suppliers for those numbers either, since upstream operators provide them. If most of your volume is bought inside the EU from operators who have already filed, your job is largely to capture and store numbers reliably.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\"><strong>Groups can use one authorised representative.<\/strong> A single EU-established entity can submit statements on behalf of group members, which helps organisations with many legal entities. Legal responsibility still sits with each operator, so internal ownership still needs to be clear. If you run a multi-entity supply base, the same logic as <a href=\"https:\/\/evaluationshub.com\/multi-entity-multi-language-supplier-onboarding\/\">multi-entity, multi-language onboarding<\/a> applies here.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\"><strong>Country benchmarking reduces effort on low-risk origins.<\/strong> Where a commodity comes from a country classified as low risk, simplified due diligence applies and a full risk assessment is not required unless a substantiated concern arises. Knowing your origin mix early tells you where the real work sits.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\"><strong>Scope has narrowed in useful places.<\/strong> Printed products such as books and newspapers came out in December 2025. The July 2026 delegated act removed cattle hides and leather, retreaded tyres, soybeans for sowing, rubber articles, belts and vehicle seats, and added soluble coffee, certain palm oil derivatives and frozen cattle tongues, with the newly added products applying from 30 December 2027. Re-checking your HS codes against the current list is one of the highest-return hours you can spend this month.<\/p>\n\n\n\n<h2 class=\"wp-block-heading\">A 14-week supplier data plan<\/h2>\n\n\n\n<p class=\"wp-block-paragraph\"><strong>Weeks 1 to 3: scope and segment<\/strong><\/p>\n\n\n\n<ol class=\"wp-block-list\">\n\n<li>Pull every purchased item against the current in-scope HS code list and confirm your own status as operator, trader or downstream actor. Scope errors are the most expensive mistake available, and they are cheap to fix now.<\/li>\n\n\n<li>Split in-scope suppliers into three groups: EU suppliers who will pass you a reference number, direct importers where you own the full due diligence, and suppliers whose status you cannot yet tell.<\/li>\n\n\n<li>Rank by volume and by origin risk. A simple <a href=\"https:\/\/evaluationshub.com\/risk-based-supplier-segmentation-a-strategic-approach\/\">risk-based segmentation<\/a> tells you which twenty suppliers deserve a phone call rather than an email.<\/li>\n\n<\/ol>\n\n\n\n<p class=\"wp-block-paragraph\"><strong>Weeks 4 to 7: launch the data request<\/strong><\/p>\n\n\n\n<ol class=\"wp-block-list\">\n\n<li>Build one request form per supplier group rather than one for everybody. A supplier passing you a reference number should not be asked for plot coordinates.<\/li>\n\n\n<li>Send it through a channel that tracks who has responded. A <a href=\"https:\/\/evaluationshub.com\/supplier-portal\/\">supplier portal<\/a> with a visible completion status beats an email campaign, because you can see the gap rather than guess at it.<\/li>\n\n\n<li>Tell suppliers why you are asking and what happens if the data is late. Suppliers respond faster to a clear commercial consequence and a named contact than to a forwarded regulation.<\/li>\n\n\n<li>Set <a href=\"https:\/\/evaluationshub.com\/automated-follow-up-for-supplier-evaluation-and-risk\/\">automated follow-up<\/a> on a fixed cadence. Response rates rise sharply with the second and third reminder, and nobody has time to chase 300 suppliers by hand.<\/li>\n\n<\/ol>\n\n\n\n<p class=\"wp-block-paragraph\"><strong>Weeks 8 to 11: assess, verify and close gaps<\/strong><\/p>\n\n\n\n<ol class=\"wp-block-list\">\n\n<li>Run risk assessment on what has arrived: check coordinates resolve to plausible plots, check legality evidence is current, and check the country classification you assumed.<\/li>\n\n\n<li>Escalate non-responders commercially. Category managers move data faster than compliance reminders do.<\/li>\n\n\n<li>For high-volume or high-risk origins, decide whether you need mitigation such as satellite checks, third-party verification or a <a href=\"https:\/\/evaluationshub.com\/digital-supplier-audits-remote-compliance\/\">remote supplier audit<\/a>.<\/li>\n\n\n<li>Treat every missing or failed data point as a tracked action with an owner and a date, the same way you would handle a <a href=\"https:\/\/evaluationshub.com\/supplier-capa-corrective-actions\/\">supplier corrective action<\/a>.<\/li>\n\n<\/ol>\n\n\n\n<p class=\"wp-block-paragraph\"><strong>Weeks 12 to 14: file and prove<\/strong><\/p>\n\n\n\n<ol class=\"wp-block-list\">\n\n<li>Register in the information system, dry-run a due diligence statement for one straightforward chain, and confirm the reference number flows to the people who need it.<\/li>\n\n\n<li>Decide which chains qualify for a single multi-shipment statement and document why, since that reasoning is what you will be asked about later.<\/li>\n\n\n<li>Make sure every decision, document and reference number sits in a <a href=\"https:\/\/evaluationshub.com\/reporting-audit-trail\/\">reporting and audit trail<\/a> that someone can navigate in minutes, with retention set to five years.<\/li>\n\n<\/ol>\n\n\n\n<p class=\"wp-block-paragraph\">If you finish the first two blocks and are still collecting in week 12, that is normal. The value of starting now is that the gap is visible while there is still time to close it.<\/p>\n\n\n\n<h2 class=\"wp-block-heading\">The data is worth more than the filing<\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">It is tempting to treat this as a compliance cost. The more useful view is that you are about to build something your organisation has wanted for years: a verified map of where your material actually comes from, down to the plot.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">That map answers questions well beyond deforestation. It tells you your true origin concentration, which is a supply continuity question. It feeds <a href=\"https:\/\/evaluationshub.com\/esg-csrd-csddd-requirements-in-onboarding\/\">CSRD and CSDDD reporting<\/a> rather than duplicating it, since much of the same evidence is requested twice under different names. It gives customers a credible answer when they flow their own requirements down to you. And it supports the wider <a href=\"https:\/\/evaluationshub.com\/supplier-esg-csrd-compliance\/\">supplier ESG picture<\/a> you are already being asked for.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">Teams that build this once, in a structured system, spend the following years maintaining it. Teams that build it in a spreadsheet for December rebuild it every time someone asks a new question. The same logic applies here as in the shift from <a href=\"https:\/\/evaluationshub.com\/annual-reviews-to-continuous-supplier-monitoring\/\">annual reviews to continuous monitoring<\/a>: the cadence you design now decides how much effort next year costs.<\/p>\n\n\n\n<h2 class=\"wp-block-heading\">Where software helps<\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">No platform makes you EUDR compliant, and any vendor who says otherwise is overselling. What good software does is remove the two things that actually break these programmes: chasing people, and losing evidence.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">EvaluationsHub handles the supplier-facing layer of exactly this work. Structured data requests with per-supplier completion tracking, automated reminders that keep the response rate climbing, documents and evidence stored against the supplier record rather than in an inbox, and an audit trail that builds itself as the team works. It connects to the rest of the supplier lifecycle too, so origin and compliance data sits beside <a href=\"https:\/\/evaluationshub.com\/supplier-scorecards\/\">supplier scorecards<\/a>, risk and corrective actions instead of in a separate silo. If you are also working through the broader due diligence agenda, our <a href=\"https:\/\/evaluationshub.com\/the-purchasing-managers-guide-to-csddd\/\">purchasing manager&#8217;s guide to CSDDD<\/a> covers the neighbouring requirement.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">If you want to see what this looks like with your own supplier list, you can <a href=\"https:\/\/evaluationshub.com\/supplier-performance-pilot\/\">run a focused pilot<\/a> or <a href=\"https:\/\/evaluationshub.com\/demo\/\">book a demo<\/a>.<\/p>\n\n\n\n<h2 class=\"wp-block-heading\">Frequently asked questions<\/h2>\n\n\n\n<p class=\"wp-block-paragraph\"><strong>When does EUDR apply?<\/strong><br\/>\nThe EU Deforestation Regulation applies from 30 December 2026 for large and medium operators and traders, and for micro and small operators that were already covered by the EU Timber Regulation. Other micro and small operators have until 30 June 2027. Products added by the July 2026 delegated act apply from 30 December 2027.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\"><strong>Which products are covered by EUDR?<\/strong><br\/>\nSeven commodities are in scope: cattle, cocoa, coffee, oil palm, rubber, soya and wood, together with many derived products including leather, chocolate, tyres, furniture and paper. The list has changed more than once, so check current HS codes rather than an older summary.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\"><strong>What supplier data does EUDR require?<\/strong><br\/>\nProduct description and HS code, quantity, country of production, geolocation coordinates for every plot of land where the commodity was produced, evidence that production was legal in the country of origin, and supplier and customer details including reference numbers of any existing due diligence statements. Records are kept for five years.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\"><strong>Do I need a due diligence statement for every shipment?<\/strong><br\/>\nNot always. A single statement can cover several shipments within a year where the material comes from the same assessed harvest events and the supply chain has not changed. Once different harvest events are involved, a new statement is needed.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\"><strong>What if I only buy from EU suppliers?<\/strong><br\/>\nYou are likely a downstream actor for much of that volume. In that case your main obligation is to collect and retain the reference numbers of the due diligence statements provided by your suppliers, rather than repeating the underlying due diligence yourself.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\"><strong>What are the penalties for non-compliance?<\/strong><br\/>\nMember States set penalties, with maximum fines for legal entities of at least 4 percent of total annual EU-wide turnover. Other sanctions include confiscation of products and revenues, temporary exclusion from public procurement and public funding, and a temporary ban on placing or exporting the products concerned.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\"><strong>Is EUDR going to be delayed again?<\/strong><br\/>\nIn its simplification review of May 2026 the Commission confirmed that the regulation will not be reopened and that existing timelines continue to apply. Planning around 30 December 2026 is the prudent assumption.<\/p>\n\n\n\n<hr class=\"wp-block-separator has-alpha-channel-opacity\"\/>\n\n\n\n<p class=\"wp-block-paragraph\"><em>Sources: <a href=\"https:\/\/environment.ec.europa.eu\/topics\/forests\/deforestation\/regulation-deforestation-free-products_en\">European Commission, Regulation on deforestation-free products<\/a>; <a href=\"https:\/\/environment.ec.europa.eu\/news\/commission-updates-product-scope-and-tools-support-eudr-2026-07-13_en\">European Commission, Commission updates product scope and tools to support EUDR, 13 July 2026<\/a>; <a href=\"https:\/\/www.consilium.europa.eu\/en\/press\/press-releases\/2025\/12\/18\/deforestation-council-signs-off-targeted-revision-to-simplify-and-postpone-the-regulation\/\">Council of the EU, Council signs off targeted revision to simplify and postpone the regulation, 18 December 2025<\/a>; <a href=\"https:\/\/www.bakermckenzie.com\/en\/insight\/publications\/2026\/05\/eu-commission-publishes-simplification-review-of-eudr\">Baker McKenzie, EU Commission publishes simplification review of EUDR, May 2026<\/a>; <a href=\"https:\/\/www.schoenherr.eu\/content\/eu-deforestation-regulation-is-your-supply-chain-ready\">Schoenherr, EU Deforestation Regulation: is your supply chain ready?<\/a>.<\/em><\/p>\n","protected":false,"gt_translate_keys":[{"key":"rendered","format":"html"}]},"excerpt":{"rendered":"<p>Just under 100 days separate us from 30 December 2026, the date the EU Deforestation Regulation starts to apply to large and medium operators and traders. Micro and small operators that are new to the rules have until 30 June 2027, although those already covered by the old EU Timber Regulation are in the December [&hellip;]<\/p>\n","protected":false,"gt_translate_keys":[{"key":"rendered","format":"html"}]},"author":5,"featured_media":0,"comment_status":"open","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"_templately_pack_id":"","_templately_imported_at":"","_templately_source":"","_templately_import_session_id":"","_jetpack_newsletter_access":"","_jetpack_dont_email_post_to_subs":false,"_jetpack_newsletter_tier_id":0,"_jetpack_memberships_contains_paywalled_content":false,"_jetpack_feature_clip_id":0,"_jetpack_memberships_contains_paid_content":false,"wds_primary_category":418,"footnotes":"","jetpack_post_was_ever_published":false},"categories":[418],"tags":[],"class_list":["post-26707","post","type-post","status-publish","format-standard","hentry","category-supplier-risk-management"],"acf":[],"jetpack_sharing_enabled":true,"jetpack_featured_media_url":"","gt_translate_keys":[{"key":"link","format":"url"}],"_links":{"self":[{"href":"https:\/\/evaluationshub.com\/api-v1\/wp\/v2\/posts\/26707","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/evaluationshub.com\/api-v1\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/evaluationshub.com\/api-v1\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/evaluationshub.com\/api-v1\/wp\/v2\/users\/5"}],"replies":[{"embeddable":true,"href":"https:\/\/evaluationshub.com\/api-v1\/wp\/v2\/comments?post=26707"}],"version-history":[{"count":0,"href":"https:\/\/evaluationshub.com\/api-v1\/wp\/v2\/posts\/26707\/revisions"}],"wp:attachment":[{"href":"https:\/\/evaluationshub.com\/api-v1\/wp\/v2\/media?parent=26707"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/evaluationshub.com\/api-v1\/wp\/v2\/categories?post=26707"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/evaluationshub.com\/api-v1\/wp\/v2\/tags?post=26707"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}