Last week we ran a webinar with our partner Resilinc, "Proving EUDR Compliance: From Plot to Product", with Ranjit Jose and Dan Emery of Resilinc alongside our co-founder and CEO Jinal Surti. Resilinc has published a full recap; this is our summary of what matters most.
For most companies, the real EUDR gap is unverified supplier data: coordinates sitting in spreadsheets that haven’t been checked against the land. Audience questions repeatedly returned to this issue, and it’s where readiness tests break.
The webinar's four-step readiness test, Resilinc's framing, is worth adopting:
- Start with a manageable set of products likely to be in scope. EUDR scope is set by HS code, so the first job is matching products and their components to Annex I, not mailing every supplier. Pick a handful of products likely to carry cattle, cocoa, coffee, oil palm, rubber, soy or wood, and use them to see what information you already hold and where the gaps are. Resilinc's advice is that nobody has to solve the whole supply chain on day one.
- Find out where your visibility stops beyond tier 1. Most companies know their direct suppliers well. Trace the regulated material upstream from each sample product and mark the tier at which the chain goes dark. That point is usually several tiers short of the farm, plantation or plot the regulation cares about, and it tells you which relationships or source information you need next.
- Validate the evidence you already have. Having a supplier declaration or a set of coordinates does not mean the requirement is met. Take a few examples and test whether each one can be verified and tied to the product it is supposed to cover. See below: this is the step we would underline.
- Run one real product through the complete workflow, from exposure to a prepared Due Diligence Statement. Identify the exposure, establish the origin, validate the evidence, engage only the suppliers step 3 showed you still need, and fill in what the statement asks for, including product mass and quantity. Wherever the process slows down or breaks is where the next improvement goes.
Step 3 is the one we would underline. The other three are organisation; this one is evidence, and it is where readiness tests break. As Jinal put it, "suppliers will send you coordinates but it's up to you to check them: does that plot exist, was it cleared after 2020, and is it actually where your material came from?" A coordinate is a claim. Evidence is the checked plot: it exists, it produces the commodity, and the land shows no clearing after 31 December 2020. In practice, take five or ten supplier-provided plots and check each against the land before you collect any more. If most of them hold up, scale the collection. If they do not, the problem is verification, not volume, and more questionnaires will not fix it.
The division of labour between us is clean. Resilinc's multi-tier intelligence shows which of your products contain regulated commodities and which suppliers they pass through. Epoch confirms which plots those commodities came from and what the land-use history of each sourcing area shows, without waiting on supplier responses.
The deadline arithmetic: large and medium operators, and all timber, comply from 30 December 2026; micro and small operators follow on 30 June 2027. Running one product end to end now shows you where the process breaks while there is still time to fix it.
One audience question deserves the last word: which other regulations can the same data serve? The EU Forced Labour Regulation, CSDDD and the Battery Regulation all ask for pieces of the same origin evidence. Build it once, for the regulation with the nearest deadline, and it keeps working after that deadline.
If you'd like to learn more about how we verify sourcing areas without supplier data, or put the product to work in your supply chain, reach out to us here.
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