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Compliance · EUDR · Process Document
EUDR Compliance Process - Executive Overview
EUDR compliance is a process, not a technology. Epoch's services walk operators through the due-diligence and Know-Your-Supplier obligations introduced by Regulation (EU) 2023/1115, from data submission to a Due-Diligence Statement (DDS) that EU TRACES will accept, with the audit trail to back it up.
The two-pillar test
EUDR places two conditions on every relevant product placed on the EU market. Both must be satisfied.
Legally produced.
Compliant with the laws of the country of production. Verified per supplier, supply base or country through documentary evidence the operator collects under Article 9.1(h); Epoch's Article 10.2 risk signals flag where to focus.
Article 9 defines the geolocation and information requirements. Article 10 defines the fourteen risk criteria. Article 11 defines mitigation when risk is non-negligible. Article 23 restricts market access for non-compliant products; Article 25 caps penalties at 4% of EU-wide turnover. The simplification package (Regulation (EU) 2025/2650) postponed application to 30 December 2026 for large/medium operators and 30 June 2027 for small/micro operators.
The six-step process
A closed loop. The first three steps move forward; supplier engagement (step 4) feeds back into the full-resolution checks (step 3) until every flagged plot is resolved; the audit trail (step 5) accumulates throughout; and only when the loop is closed does the DDS lodge with EU TRACES (step 6).
Supplier data submission
plot polygons (preferred) or a first-mile aggregation point. Operator-provided.
Initial risk screening
real-time. Article 10.2 (a)–(n), plus legality and governance signals. Deterministic + AI-assisted.
Full-resolution deforestation checks
12 h turnaround. Six-source ensemble + natural-forest mask. Deterministic.
Supplier engagement
conditional. Triggered when Article 10 risks or specific plots flag. Operator-led, logged.
Audit trail
continuous, immutable. Every operation timestamped and dataset-versioned.
DDS submission to EU TRACES
operator-signed, or Epoch on behalf as authorised representative.
Operator vs. Epoch responsibilities
The operator placing the product on the EU market is the legally accountable party under EUDR Articles 8–13. The work is split: Epoch operationalises the methodology and the audit trail; the operator brings supply-chain knowledge, evidence Epoch cannot manufacture, and the final-judgement calls the regulator expects. The legally binding compliance determination remains the operator's.
| Obligation | What the operator provides | When | What Epoch handles |
|---|---|---|---|
| First-mile data (Article 9 geolocation) | Plot polygons or first-mile aggregation points | Before first submission per supplier; refresh on sourcing change | Validation, normalisation, geocoding; supply-shed delineation; commodity-detection stack derives plots from a shed |
| Article 9 TRACES fields | Factual values | Per DDS submission | TRACES-schema pre-validation; structured capture in audit trail |
| Legality evidence (Article 9.1(h)) | Primary documents (titles, permits, certifications, audit reports, training records, grievance logs) or proxy evidence with a written explanation | Per supplier; refresh ≥ annually | Surfaces relevant laws via Article 10.2 (h)(l)(m) signals; structures engagement to timestamp evidence |
| Supplier engagement on flagged plots | Reach out, request evidence, decide exclusion / further evidence | Per flag | In-platform engagement channel; audit-trail capture of every request, response and upload |
| Risk determination (Article 10.6) | Final judgement call (legally the operator's) | Per DDS submission | Composite Article 10 score, per-criterion breakdown, deforestation verdict |
| Article 11 mitigation | Operational artefacts (training, audit cycle, grievance log, evidence-of-effect) | Ongoing for non-negligible-risk suppliers | Engagement channel; structured capture of mitigation evidence by supplier and period |
| Audit-trail retention (Article 12, 5 yr) | Legal duty | Continuous | Platform retention for the full 5-yr period; CA event-log export on request |
| DDS submission | Legal responsibility for accuracy | Per shipment | Submission via Epoch's TRACES integration as authorised representative if appointed |
Evidence depth is risk-proportional, per Articles 10.6 and 13:
- Article 9 obligations are not negotiable by risk. Plot polygons and the Article 9.1 information set are required at the same depth regardless of perceived risk.
- Articles 10 and 11 scale with risk. For sources benchmarked low-risk by the Commission under Article 29, simplified due diligence under Article 13 lifts the Article 10 / 11 burden entirely while keeping Article 9 in place.
- "Low risk" is the score, not the gut feel. Anchored on the §5.5-equivalent composite Article 10 score and the Article 29 benchmark, not intuition.
Two input modes
What "plot" means. A homogeneous area actively growing (or, for cattle, used to raise) the target commodity, a contiguous patch that behaves as one unit from a remote-sensing perspective. This is exactly EUDR Article 2(27)'s definition: "land … which possesses sufficiently homogeneous conditions to allow an evaluation of the aggregate level of risk … associated with relevant commodities produced on that land". A plot is a functional unit, not a cadastral parcel: per FAQ 1.6, "the absence of a land registry or formal title should not prevent the designation of land that is de facto used as a plot of land."
Plot locations.
The operator provides exact production plots — polygons for plots over 4 ha, point + plot-area for plots under 4 ha. The gold standard: every check runs against the actual sourcing footprint.
First-mile aggregation points.
The operator provides a single coordinate or navigable address: sawmill, palm mill, soy silo, washing station, slaughterhouse, cooperative buying centre. From that single point, Epoch generates a commodity-specific supply shed (a travel-time isochrone calibrated per commodity), detects every plot of the target commodity inside that shed directly from satellite imagery, and runs compliance checks across that detected set — a superset of what the operator actually sources from. This is the "declaration in excess" posture: a stricter bar than the regulation requires.
The commodity-detection stack: Forest Data Partnership (FDP) layers for palm/cocoa/rubber/coffee, GLAD annual soy mapping for soy, Global Pasture Watch for cattle, and Epoch's harvest-event detection for timber.
Per-commodity supply-shed defaults
Cattle
Default 180 min
Approx. one-way distance ≈ 100–150 km
First industrial aggregation point Slaughterhouse (state-licensed / SIE)
Soy
Default 120 min
Approx. one-way distance ≈ 30–80 km
First industrial aggregation point Grain elevator / trading post
Palm oil
Default 90 min
Approx. one-way distance ≈ 50 km
First industrial aggregation point Palm-oil mill
Timber
Default 180 min
Approx. one-way distance ≈ 60–100 km
First industrial aggregation point Sawmill
Rubber
Default 120 min
Approx. one-way distance ≈ 60–80 km
First industrial aggregation point Crumb rubber / RSS factory
Cocoa
Default 90 min
Approx. one-way distance ≈ 22–40 km
First industrial aggregation point Cooperative fermentation & drying centre
Coffee
Default 60 min
Approx. one-way distance ≈ 25–35 km
First industrial aggregation point Cooperative wet mill (washing station)
Operators can override these defaults (long-haul transport, river-supplied basins, federally-licensed slaughterhouses) or substitute an administrative-jurisdiction boundary. Timber is a special case: the supply-shed pipeline detects harvest events (clear-cuts, selective cuts) over a configurable look-back window (default 1 year), and treats each detected harvest patch as a plot.
Initial risk screening
Resolution: ≈ 30 m (crude first pass). Turnaround time: real-time.
A single synchronous call returns five outputs across the supplier portfolio:
- Location validation — geometry hygiene, jurisdiction containment, commodity-presence checks, statistical implausibility (regular grids, cherry-picked clusters).
- Crude deforestation check — 30 m forest-loss screen against EU-cited reference datasets (JRC TMF, Hansen GFC, MapBiomas).
- Article 10.2 risk assessment — every Article 10 criterion is scored with one of three method classes: 🟦 deterministic (pixel-level overlay against named, versioned datasets), 🟨 LLM + grounding (open-web evidence aggregation for governance / corruption / human-rights signals — flags risk, never decides), or 🟩 operator-supplied (FPIC documentation, certifications, internal traceability data).
- Infrastructure risk — proximity to roads, ports, processing infrastructure (OSM, GFW).
- Natural-hazard exposure — fire, flood, drought, landslide. Not a compliance signal; surfaced for forward-looking supply-continuity decisions.
The Article 10.2 composite score classifies each supply base into one of three tiers, which drives the evidence-collection burden:
- Low (score < 5): simplified DD under Article 13 may apply where the country is Commission-benchmarked low-risk. Article 9 information still required.
- Medium (5–7): standard DD. Full Article 9.1(h) pack; Article 11 mitigation only for the specific flags that fire.
- High (≥ 8): enhanced DD. Primary documents preferred over proxies; recent audit cycles; active Article 11 mitigation; recurring re-assessment.
Full-resolution deforestation checks
Resolution: 10 m. Turnaround time: ≈ 12 h.
A 10 m multi-source ensemble run against the 31 December 2020 cutoff:
- Four near-real-time alert systems: GLAD-L, GLAD-S2, RADD (Sentinel-1 radar, cloud-penetrating), OPERA DIST-ALERT (NASA, Harmonized Landsat–Sentinel-2).
- One annual institutional product: JRC TMF.
- One Epoch-operated time-series breakpoint detector: CCDC (Zhu & Woodcock 2014).
Each pixel of forest change reports the count of systems in agreement and a derived confidence band. The natural-forest reference mask combines DeepMind Natural Forest of the World (10 m) and JRC TMF (30 m); managed-forest tenure-exemption layers for 19 jurisdictions (Canada, USA, Estonia, Latvia, Lithuania, Australia, New Zealand, Brazil, Chile, South Africa, Indonesia, Portugal, Uruguay, Norway, Sweden, Finland, Poland, Denmark, Slovenia) are applied. Every dataset version used is logged in the audit trail so any result can be reproduced under audit months later.
Supplier engagement
Two triggers escalate from automated checks to direct supplier engagement:
Initial-screening flags
elevated Article 10 risk fires before full-resolution analysis. The operator engages on the relevant category (governance, FPIC, sanctions, labour, supply-chain integrity). Sanctions matches are a stop-the-line.
Full-resolution flags
specific plots fail the 10 m check. Engagement is per plot: the supplier provides justifications for exclusion or non-compliance rebuttal.
Engagement happens in-platform: requests are templated per Article 10.2 category, sent with the relevant evidence pack pre-attached; responses (geojson, PDF, free text) are captured back into the audit trail. The full doc carries an operator evidence reference table mapping each evidence category (plot polygons, legality documents, third-party audit reports, sanctions screening, FPIC records, certifications, mitigation artefacts) to its Article-and-tier requirement, primary vs. acceptable-proxy form, and upload path (flag-driven engagement thread or standalone operator-initiated upload).
Audit trail and DDS submission
Every operation against a DDS — initial screening, full-resolution check, supplier engagement, justification upload, exclusion decision, final DDS export — is logged with UTC timestamp, dataset versions, geometries (input and derived), and provenance labels (deterministic vs. probabilistic). Compliance status is computed from the trail rather than stored as a flat field, so status and evidence cannot drift apart. Operators can attach standalone supporting documents to the audit trail at any time — legacy evidence packs, third-party assessments, internal compliance memos — so anything that backs the DDS but isn't formally submitted to TRACES has one home.
DDS submission: Epoch pre-validates the geojson and the Article 9.1 fields against the TRACES schema; either operator-signed (the operator controls the submission) or on-behalf-of (Epoch submits as authorised representative and returns the reference + verification number). The audit trail is retained for the full 5-year Article 12 period and is exportable on competent-authority request.
Deterministic vs. AI-assisted: the division of labour
Compliance verdicts are always produced by deterministic rules. Pixel-level overlay against named, versioned datasets (JRC TMF, GLAD L/S2, RADD, OPERA DIST, CCDC), with a uniformly-applied natural-forest mask. Any inspector can re-run a single plot from the same inputs and reach the same verdict.
AI-assisted components flag risk for engagement; they never decide compliance. Open-web evidence aggregation for Article 10.2 (h)(l)(m) (corruption, sanctions, news-based concerns) is surfaced separately with citations to dated, geographically-relevant sources. The Method column on the Article 10.2 table labels every criterion's provenance, so the basis of every flag is legible at the point it is raised.
Commodity quick reference
Soy
EUDR readiness Medium
Structural problem Sub-national risk concentration (Trase); early mixing at country/terminal elevators
Key national / industry rails CAR (Brazil), AFIP (Argentina), RTRS, Donau Soja / Europe Soya
Timber & pulp
EUDR readiness Medium, high variance
Structural problem Broadest product scope (logs → furniture); industrial plantations vs. natural-forest concessions
Key national / industry rails SVLK (Indonesia), DOF / Sinaflor+ + CAR (Brazil), FLEGT TLAS, FSC / PEFC
Cattle
EUDR readiness Low–medium
Structural problem Birth → rearing → finishing → slaughter on different farms; indirect-supplier traceability gap
Key national / industry rails GTA, SISBOV, CAR (Brazil); NLIS (Australia); SENASA (Argentina); National RFID (Uruguay)
Rubber
EUDR readiness Low–medium
Structural problem 80–85% smallholder-grown; cup-lump vs. latex drive different shed sizes; West Africa scaling rapidly
Key national / industry rails GPSNR, FSC / PEFC, Rainforest Alliance, Fair Rubber Association; RAOT (Thailand)
Coffee
EUDR readiness Medium
Structural problem Wet vs. dry processing splits the geography; smallholder-dominated
Key national / industry rails FNC (Colombia), eATTS (Ethiopia), CONAB (Brazil), UCDA (Uganda); Rainforest Alliance, 4C, Fairtrade
Cocoa
EUDR readiness Medium
Structural problem West-African concentration; cooperative-level deforestation hot-spots; first-buyer (not first-farmer) documentation
Key national / industry rails GCTS (Ghana), SYDORE (Côte d'Ivoire), CFI, Rainforest Alliance, Fairtrade
Palm oil
EUDR readiness Medium–high
Structural problem Smallholder polygons missing in Indonesia/Thailand; pre-refinery mixing; peatland exposure
Key national / industry rails RSPO (10.2(n) evidence base), Universal Mill List, Trase; MPOB (Malaysia), GAPKI (Indonesia), Fedepalma (Colombia), NDPE
Top FAQs
The full reference carries the full FAQ set. The shortlist operators ask most often:
- "Can a DDS be edited or revoked after submission?" No. The EU TRACES API has no operator-facing amend operation; the only path to correct an error is to file a new DDS. The regulator's accuracy obligation rests on the operator at submission time.
- "Does AI make compliance decisions?" No. Compliance verdicts are deterministic. AI-assisted components only flag risk for engagement.
- "Our supplier has FSC / PEFC Chain of Custody certificates but no harvest locations — is that enough?" No. FSC / PEFC CoC are administrative site certificates accepted as Article 10.2(n) supplementary evidence, but they don't meet the Article 9 geolocation bar. The supplier needs to provide at minimum a sub-national region or, better, a mill / first-mile-facility address.
- "Does our upstream smallholder's MSPO simplified-declaration status let us skip our own DDS?" No. MSPO status applies to the primary producer placing directly on the EU market. It doesn't transfer downstream. An EU retailer sourcing from an MSPO is itself a standard operator with full DDS obligations.
- "Can a single DDS cover multiple products, including across commodities?" Yes (FAQ 5.19 + FAQ 3.29). The practical constraint is the TRACES ≈ 25 MB file-size cap, not the per-DDS line limits, so operators with deep supply bases typically end up filing multiple DDSs per product family anyway.
- "For composite products with raw materials of different HS codes, which HS code goes on the DDS?" The finished-product HS code, the one customs anchors on. The DDS body still lists all production plots for the underlying materials. For multi-commodity composites (FAQ 1.3), DD extends only to the main commodity Annex I links to the finished product.
The Epoch EUDR Compliance Process — Executive Overview. For the full methodology, per-criterion detail, per-commodity operational notes, full FAQ set, glossary, and source citations, see The Epoch EUDR Compliance Process (full reference).
Need the full methodology, per-criterion Article 10.2 detail, per-commodity operational notes, and complete FAQ set? Download the full reference (PDF) →
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Download the typeset executive overview, print-ready for sharing with compliance teams, legal counsel, or competent authorities. For the full methodology and per-criterion detail, see the full reference PDF.