As the EU Deforestation Regulation (EUDR) comes into effect, businesses across supply chains are grappling with new compliance requirements. At Interu, we understand the complexity and nuances of preparing for new regulations so we are here to help you navigate them seamlessly. We’ve compiled answers to the most common questions we’ve been asked so far in 2025 about EUDR compliance and how our platform supports your business.
Sources:
- REGULATION (EU) 2023/1115 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
- EU FAQs (OCTOBER 2024) - IMPLEMENTATION OF THE EUDR
1. I’m certified – why do I need Interu?
Certification schemes like FSC or PEFC are valuable, but they do not fully cover all the requirements of the EU Deforestation Regulation. The EUDR mandates specific and traceable information that goes beyond traditional certification:
- Geolocation Data: Certification does not typically provide precise geolocation coordinates required by the EUDR.
- Deforestation-Free Assurance and Risk Assessment: The EUDR requires a clear demonstration that products do not originate from recently deforested or degraded land for each consignment. Certification indicates that an organisation’s systems and processes meet a given standard, but does not indicate that real-time consignments of products are EUDR compliant.
- Supply Chain Transparency: Companies must maintain an auditable due diligence system that includes comprehensive supply chain data and regular risk assessments.
Generally, FSC or PEFC Forest Management (FM) and Chain of Custody (CoC) certification seek to ensure that products are sourced from responsibly managed forests but do not require the end-to-end product traceability mandated by the EUDR.
While both certification schemes have introduced optional modules to address EUDR requirements - such as the voluntary EUDR (PEFC) module or the Regulatory (FSC) module - these still require businesses to conduct thorough assessments tracing the entire supply chain back to the source on a consignment level.
Many organisations source a variety of products that individually will have a different status which could be FSC, PEFC or non-certified, making it challenging to track and verify compliance consistently. Even with the voluntary modules, managing multiple product sources under separate frameworks can create complexity and gaps in traceability.
Interu addresses these challenges by offering a unified platform that manages the end-to-end traceability of all product types - whether FSC, PEFC, or non-certified. It enables businesses to collect, verify, and store the required data for EUDR compliance, providing a comprehensive view across supply chains and facilitating seamless reporting.
Interu facilitates this by providing a platform to collect, verify, and store the necessary data, enabling you to reach compliance with minimal disruption to your operations.
Refer to the 3rd Iteration of the official, non-binding FAQs from the EC, FAQ 5.7 and (52) in the regulatory text itself: “In order to recognise good practice, certification or other third-party verified schemes could be used in the risk assessment procedure. They should not, however, substitute the operator’s responsibility as regards due diligence.”
2. I’m outside of the EU – can I submit to TRACES NT?
Yes, non-EU established companies are able to submit to Traces NT if you are listed as the importer or consignee of record when importing goods into the EU. To submit information to the EU’s TRACES NT system, you will need an EORI (Economic Operators Registration and Identification) number. This identifier is essential for customs and ensures your goods can be legally imported into the EU.
If you are a non-EU established entity, supplying EU-based customers, and your customers are in-scope of EUDR but you are not the importer of record, your customer is highly dependent on you to provide data which will enable them to conduct due diligence and risk assessment on the full supply chain. Whilst you may not be legally responsible for submitting the Due Diligence Statement to TRACES NT, you still need to collect and pass on critical information.
Indeed, if you are a non-EU established entity, buying in-scope goods from the EU, and potentially re-exporting them to the EU, then you are obliged to pass on the Due Diligence reference number which your EU-based suppliers will have created on exporting goods to you (please see the diagram under the next question).
Interu’s integration helps businesses manage the submission process, ensuring the correct data is formatted and ready for TRACES NT, streamlining your access to the EU market.
Refer to the 3rd Iteration of the official, non-binding FAQs from the EC, FAQ 1.3 (“There are no legal obligations applicable to non-EU countries”) and FAQ 3.7 (“If a natural or legal person established outside the EU places relevant products on the market, according to Art. 7 EUDR the first person established in the Union who makes such products available on the market should be deemed to be an operator within the meaning of the Regulation.” and “Non-EU based operators will only have access to the Information System if they have a valid EORI number, as only in this case they will need to submit a due diligence statement after having conducted due diligence prior to lodging a customs declaration. They will have access to the system in the role of an operator and not as an authorised representative, as according to Art. 2(22) of the Regulation, the authorised representative must be established in the Union.”)
3. What if I’m trading within Europe – do I still need to maintain a Due Diligence Statement?
Yes, even intra-European trade is subject to EUDR requirements. The regulation applies to imports into the EU, exports and movements of covered products within the region.
For example in the diagram below, if you import in-scope raw materials (such as round wood) into the EU and process them into pulp in one EU country and sell them in other countries (EU or otherwise), you must:
- Submit a DDS in TRACES NT and obtain a Reference Number on import of the round wood: This number accompanies the original import declaration.
- Create a new TRACES NT Reference Number, linked to the first one, after you process the round wood and before you place the product on the market.
- Pass the Reference Number Downstream: When you sell the processed product (pulp, then paper (in the diagram below)), you must share the TRACES NT reference with your buyers to maintain the chain of compliance.
Each time an Operator or Trader places goods on the market for the first time (i.e., the first time in their given form), they need to create a Due Diligence Statement, referring back to linked upstream reference numbers. A good way to consider this is if the HS code of the product changes following processing within the EU, the product will be being placed on the market for the first time (in that form), and therefore due diligence is required to manage risk of mixing in the manufacturing process.
Interu makes it easy to track and transfer this information across your supply chain, reducing administrative burdens while ensuring full regulatory adherence.
Refer to (23) in the regulatory text itself: “The scope of this Regulation should therefore include commodities and products produced within the Union as well as commodities and products imported to the Union.” and the 3rd Iteration of the official, non-binding FAQs from the EC, FAQ 2.4: “Commodities produced inside the EU are subject to the same requirements as products produced outside the EU. The Regulation applies to products listed in Annex I, whether they are produced in the EU or imported.”
4. What if I’m sourcing from China?
When sourcing materials processed in China, the origin of the raw materials remains critical under the EUDR:
- Processed Goods: If you source a product like a wooden table manufactured in China but made from Malaysian wood, the geolocation coordinates must reflect the forest in Malaysia where the timber was harvested.
- Chinese-Origin Materials: If the raw materials originate in China and geolocation data cannot be provided (as some Chinese suppliers are unable to share this information), a Due Diligence Statement cannot be completed and submitted to Traces NT. Therefore the products will not obtain customs clearance and, as a result, the products cannot be imported into the EU (see example image below from the Traces platform, showing the error message received if you don’t have geolocations when submitting a DDS).
Interu assists by helping you trace back to the true source of your raw materials and ensuring your suppliers meet the EUDR’s transparency standards.
5. How can I prove that there are no links to deforestation in my supply chain?
The EUDR mandates specific and traceable information back to the forest (source). These include:
- Geolocation Data: The EUDR mandates that geolocation data of the area of production must be collected and submitted by the operator (who first places, or makes available, the commodity within the EU) into Traces NT.
- Deforestation-Free Assurance: The EUDR requires a clear demonstration that products do not originate from recently deforested or degraded land. This could be in the form of a deforestation analysis provided by a satellite landscape assessment provider, whereby comprehensive historical deforestation analysis, on the land from where the commodity has been harvested, from 31 Dec 2020 onwards, has been conducted.
- The aim of this exercise is to understand historical patterns and impacts of deforestation over time within the area of production, and to enable the operator to be in a confident position to declare negligible risk of deforestation within the supply chain, and prove legal compliance with the EUDR in a due diligence statement.
- Detailed Traceability: From the forest to the customer in the form of tracking and transactional traceability e.g. recording and ensuring full visibility of all transactions along supply chains, as well as recording of accurate information and documents, and verification of traceability information back to the forest.
- This is critical to be able to link the plots of land you have assessed for deforestation risk to the products sourced from them, processed and shipped downstream.
How Interu Simplifies EUDR Compliance
Interu is designed to support businesses at every stage of the supply chain. We provide:
- Centralised Data Management: Securely collect and store geolocation, supply chain records, and due diligence data.
- TRACES NT Integration: Prepare and submit compliant declarations with ease.
- Audit-Ready Documentation: Ensure you have the required documentation available for inspections.
Whether you're an EU-based importer, an overseas manufacturer, or a trader within the EU, Interu empowers you to stay ahead of regulatory changes and maintain seamless market access.
Have more questions? Contact us today to learn how Interu can help your business navigate the EU Deforestation Regulation with confidence.
