The EU Deforestation Regulation (EUDR) compliance deadline for large and medium operators is less than nine months away: 30 December 2026. With the recent launch of the EUDR Community of Practice—a multi-stakeholder forum co-facilitated by the EU Sustainable Supply Chains Coalition and the European Forest Institute (EFI)—the conversation in the sector has officially shifted from whether to comply, to how.
At the launch event on 11 March 2026, EFI presented findings from 4 voluntary EUDR dry runs they facilitated in 2025. These covered coffee and palm oil supply chains, involved 4 operators, 5 competent authorities (Belgium, Netherlands, Germany, France, and Spain), and sourced from 10 countries across Africa, Latin America, and Southeast Asia. Each exercise simulated the full inspection workflow in 3 parts: first, a due diligence statement submission to the EUDR IT system, second, a virtual check on the operator's due diligence system, and third, a face-to-face simulated inspection. The full reports are publicly available at efi.int/partnerships/valuechains .
EFI was careful to note that these findings represent emerging good practice—not definitive compliance positions from the participating authorities. With that important context, here are the 10 lessons, and how Epoch helps operators address them.
Lesson 1: Geometry Checks Improve Geolocation Quality
Before any inspection begins, competent authorities review the geospatial data in the due diligence statement. In every single dry run—even among well-prepared operators—authorities found issues:
- Duplicate geometries caused by map projection errors (the EUDR requires all data in WGS84)
- Single-point coordinates placed on residential houses rather than within plots
- Inconsistent polygon boundaries from different service providers applying different methodologies to the same sourcing area
EFI recommends a 5-point geometry check as good practice before any DDS submission: (1) duplicates, (2) overlaps, (3) self-intersections, (4) spikes, and (5) illogical locations such as plots in water, in another country, or outside production areas.
🌿 HOW EPOCH HELPS
Epoch's platform automatically generates and validates field boundaries of commodity-growing areas—even across fragmented smallholder landscapes—and runs continuous geospatial QA flagging to identify common errors before they reach a competent authority. With 120M+ hectares already analyzed, polygon validation is a core part of every operator workflow on the platform.
Lesson 2: Cross-Referencing Multiple Maps Builds Confidence
Competent authorities consistently found that single-dataset approaches were insufficient. For example, in Honduras, crossing a polygon with the 2018 land use map revealed a coffee plantation, while the 2024 map showed the area reclassified as forest. However, the commodity map showed no coffee inside the polygon—demonstrating exactly why convergence across sources matters.
Cross-referencing examples from EFI’s dry runs included JRC forest maps with global datasets such as GFW, national monitoring programs like PRODES (Brazil), and commodity-specific maps when forest data were limited.
🌿 HOW EPOCH HELPS
Epoch integrates global deforestation datasets, satellite-derived land use change detection, national forest monitoring layers, and commodity land use maps into a single converged risk picture—delivered at plot and supply shed level. This convergence-of-evidence approach is exactly what competent authorities are looking for, and it is built into Epoch's standard monitoring workflow. Our supply shed methodology was designed precisely for this kind of multi-source, landscape-level assessment.
Lesson 3: A Simple "Deforestation-Free" Statement Is Not Sufficient
Despite operators having done the necessary analytical work, one of the most consistent patterns EFI observed was an inability to explain their reasoning to inspectors. Competent authorities expect operators to walk through the steps that led to a negligible-risk conclusion, including how false positives (detected changes that turned out not to be deforestation) were identified, assessed, and resolved.
As one participating competent authority stated, “if there is an overlap between the JRC 2020 forest map and plots linked to a shipment, operators must be able to explain how that was dealt with”. Good practice involves not only documenting the full methodology and recording all findings, including false positives, but also describing any follow-up field verification that occurs. This challenge is amplified when operators outsource risk assessment to service providers because the burden of explanation remains with the operator, not the provider.
🌿 HOW EPOCH HELPS
Every deforestation check run through Epoch's API is fully logged. Data sources, assessment methodology, findings, and conclusions are all stored in a plot-level, timestamped, auditable record with visual thumbnail support. When an inspector asks "how did you reach this conclusion?", operators have a documented evidence trail, not a call to their service provider.
Lesson 4: Plot-Level Focus Limits Understanding of Broader Landscape Risks
Looking only at whether sourcing plots are deforestation-free is not enough. Competent authorities expect operators to assess deforestation inside and around the plot. Areas with recent or ongoing disturbance, even if they are outside a supplier's specific plots, are treated as high-risk landscapes, potentially indicating deforestation pressure, weak governance, or informal expansion.
This matters because landscape-level disturbance linked to the sourced commodity increases the risk of mixing compliant and non-compliant products in the supply chain. Recommended mitigation measures for high-risk landscapes include robust traceability systems, effective segregation from unknown or unverified sources, and continuous monitoring of landscape changes. Spatial data should be complemented with NGO reports, media, and whistleblower sources.
🌿 HOW EPOCH HELPS
Epoch's supply shed analysis maps the broader sourcing landscape beyond individual plots to identify deforestation pressure, commodity expansion, and environmental risk at the landscape level. This is the foundation of the risk contextualization that competent authorities require, and it is built into Epoch's standard monitoring workflow.
Lesson 5: Legality Due Diligence Begins With Identifying the Right Laws
Operators often overlook the first critical step in legality due diligence: identifying which national laws are relevant to their country of production under EUDR Article 9. Those relying on certifications or external providers frequently lack insight into this foundational step, despite competent authorities expecting operators to own it.
EFI outlined a recommended sequence:
- Understand the country of production and its legal and administrative framework
- Identify the relevant legal requirements and map them to EUDR criteria
- Understand how those requirements apply to the area of production
Legality due diligence must also distinguish between estates and smallholders, account for sub-national legal complexity, and consider long-standing issues flagged in NGO or credible third-party reports. As one competent authority stated plainly, “a list of relevant laws alone is not enough”, operators must demonstrate how the plots included in their DDS actually comply with those laws.
🌿 HOW EPOCH HELPS
Epoch's data infrastructure connects plot-level information to country and regional-level legal risk profiles, enabling operators to ground their legality assessments in actual sourcing geography rather than applying generic country frameworks uniformly.
Lesson 6: Legality Due Diligence Is an Evidence-Based Assessment, Not a Document Collection Exercise
A recurring observation across the dry runs was operators approaching legality due diligence as a document-collection task. EFI was clear that this is a misreading of the regulation. Under EUDR Article 9, legality can be demonstrated through information, documents, and data—when primary documents are incomplete or unavailable, proxy evidence is explicitly relevant. The key is not simply citing a document, but explaining how it meets specific EUDR requirements.
🌿 HOW EPOCH HELPS
Epoch's platform enriches sourcing geography with third-party proxy datasets—including World Bank governance and rule of law indicators, Transparency International corruption indices, protected area registries (WDPA), intact forest landscape maps (IFL), and land tenure records—and surfaces locally relevant contextual information such as regional media reports, enforcement actions, and authoritative sources specific to the area of production. This builds a location-specific evidence base that supports the kind of evidence-based legality assessment competent authorities are looking for, grounded in actual sourcing geography rather than generic country profiles.
Lesson 7: National Databases Can Facilitate Legal Compliance Verification If Used Correctly
Under the EUDR, the burden of proof remains with the EU operator. However, legal documents often cannot be retained by the operator without supplier consent. The dry runs surfaced a practical solution: national government databases, such as Indonesia's SIPERIBUN system for plantation data, can allow operators to verify the validity of legal documentation without holding the originals.
Still, EFI was clear that national databases are one layer of evidence, not a substitute for verification. Good practice involves treating national data as a starting point, cross-checking with independent sources in higher-risk areas, and verifying through sample or ground checks. Operators should be prepared to clearly demonstrate how national information systems are used and how their reliability was assessed.
🌿 HOW EPOCH HELPS
Epoch's plot-level monitoring outputs—including deforestation thumbnails, commodity verification, and risk flags—enable operators to target supplier engagement where it matters most, rather than requesting blanket documentation from every producer. For legality spot checks, Epoch can derive risk-stratified sampling plans that prioritise plots with elevated risk indicators, reducing the operational burden on producers while ensuring verification effort is concentrated where competent authorities would expect it. This turns the audit trail into an actionable tool for field verification planning, not just a compliance record.
Lesson 8: Credible Risk Assessments Are Nested From Country Level to Supply Chain Level
Global and national datasets alone have limited value when they aren't connected to the operator's actual supply chain. EFI observed that stronger operators used nested risk assessments: a country-level assessment for each relevant legal or environmental risk, followed by a supply chain-level assessment for their actual suppliers and producers. Ultimately, documenting where the two levels diverged and why.
Where supply chain-level evidence reduced the country-level risk picture, operators documented the reasoning. Where risk couldn't be discarded, mitigation measures were triggered. NGO reports on land rights, human rights, and environmental issues were identified as valuable inputs for strengthening legality risk assessments at both levels.
🌿 HOW EPOCH HELPS
Epoch's platform natively supports nested risk assessment—country-level indicators (governance indices, deforestation baselines, protected area coverage) are automatically contextualised against plot- and supplier-level monitoring data for each assessment. Where supply chain evidence diverges from the country-level risk picture—for example, a high-risk country but consistently compliant plots—the platform surfaces that contrast, enabling operators to document their reasoning. Our first-mile mapping data consistently shows that environmental risk is highly concentrated: the bottom 5–10% of producers typically drive the majority of deforestation and emissions, and our platform identifies and documents this as part of the standard assessment process.
Lesson 9: Mitigation Measures Must Be Targeted, Verifiable, and Operational—Not Just Documented
Risk mitigation was identified as one of the areas where operators struggled most. It is not enough to describe mitigation measures in a due diligence system; competent authorities expect evidence that they work in practice. Self-assessment reports and codes of conduct were explicitly identified as weak mitigation evidence on their own, particularly for addressing risks of mixing and traceability gaps at the plot level.
The key question competent authorities asked: how does the operator verify that plots detected with deforestation are not only removed from their data systems, but also excluded from their actual sourcing and supply chain? Practical evidence included records of supplier training on segregation, audits for high-risk suppliers, accessible grievance mechanisms with documented follow-up, and certification schemes—but only when they cover legal requirements, include robust audits, and prevent mixing of certified and non-certified products.
🌿 HOW EPOCH HELPS
Epoch's continuous monitoring creates a timestamped record of when risks are detected and how they evolve—enabling operators to demonstrate that mitigation measures are operational, not just described. When plots are flagged for non-compliance, Epoch's supplier engagement interface allows producers to confirm and document the exclusion of flagged locations, or to provide evidence that a detection is not true deforestation—creating a verifiable, auditable record of the decision and its justification. Combined with risk-stratified sampling plans (see Lesson 7), operators can present competent authorities with a documented chain of action: detection, producer engagement, documented resolution, and ongoing verification.
Lesson 10: External Tools Support Due Diligence, But Cannot Replace Operator Responsibility
All four operators in the dry runs used certification schemes and third-party service providers. While these tools add value, competent authorities were consistent: operators cannot delegate risk assessment. As EFI summarized, "you must understand, verify, and defend the evidence behind any conclusions”.
For certification schemes, this means using certification as supporting evidence rather than proof of compliance, and being transparent about which suppliers or volumes are certified. For third-party service providers, this means:
- Understanding the data, models, and thresholds used
- Independently cross-checking analysis against national maps and field checks
- Documenting how third-party information was validated and incorporated into the due diligence system
🌿 HOW EPOCH HELPS
Epoch is transparent by design. Our methodology is documented in public whitepapers, our data sources are disclosed, and our API outputs are structured specifically for integration into operator due diligence systems. We exist to make operators smarter about their supply chains, not to be a black box that certifies compliance on their behalf.
The Overarching Message: From Document Culture to Evidence-Based Practice
Across all 10 lessons, a unifying theme emerged: the industry needs to move away from a document culture—the assumption that collecting the right paperwork is equivalent to demonstrating compliance. The EUDR demands a genuinely evidence-based approach, where methodology is transparent, conclusions are explained, mitigation is operational, and the whole system is continuously improving.
EFI described this as a "joint learning process," and competent authorities engaged in the dry runs in a spirit of cooperation—not gotcha enforcement. But the exercises were clear: operators who have invested in their systems still need to invest in their ability to explain and defend those systems. That is the remaining gap for many.
With the December deadline approaching, and more dry runs planned for 2026 through the EUDR Community of Practice, the time to act is now.
Epoch Blue is the most comprehensive first-mile visibility platform for agricultural and forestry supply chains—monitoring 10M+ farms and 120M+ hectares for deforestation, biodiversity, water, and carbon metrics. Trusted by Assent, Altana, Golden Agri Resources, Sphera, WWF, and others, Epoch combines AI-driven plot detection, multi-source convergent geospatial analytics, and an API-first architecture to deliver audit-ready EUDR compliance evidence at scale.
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Source: EFI, "Insights from EUDR Dry Runs: Key Challenges and Emerging Best Practices," EUDR Community of Practice Launch Event, 11 March 2026. Full reports available at efi.int/partnerships/valuechains .
Thanks to the EU Sustainable Supply Chains Coalition and the European Forest Institute for the transparency of these findings.
