EUDR Compliance: Due Diligence & Key Deadlines
In 2025, Dutch authorities conducted pilot inspections across 20 operators and found widespread shortcomings in due diligence documentation. Dry runs led by German, Belgian, Dutch, and French regulators confirmed that authorities expect a complete "paper trail" for each specific shipment — not just a general due diligence system on paper. Rotterdam, Europe's largest port, is now a regulatory checkpoint where shipments without verified geolocation data can be stopped.
A cocoa importer we onboarded last quarter had their entire shipment flagged at Rotterdam port. The problem wasn't that their supply chain was deforestation-linked — it was that they couldn't produce the geolocation data fast enough. On the Sustalium platform, we see this pattern repeat across commodities: the legal burden is on the importer, not the supplier.
The EU Deforestation Regulation (EUDR — Regulation [EU] 2023/1115) is now fully enforced. Unlike voluntary sustainability pledges, it makes it a criminal offense to import commodities produced on land deforested or degraded after December 31, 2020. The burden of proof is entirely on your business.