Update from Brussels: What’s New for EUDR and How TRACT Has You Covered
The European Commission has released a Draft Delegated Act alongside updated Guidance and Frequently Asked Questions to provide more clarity on the implementation of the Regulation on Deforestation-free Products (EUDR). Together, the new documents are nearly 90 pages so here’s a breakdown of key updates – and how TRACT helps you stay on track for compliance.
Product samples and packing materials used to support, protect or carry another product are out of scope.
The draft Delegated Act* clarifies which products fall outside the scope of EUDR. This includes small samples, items used only for testing (if fully used or destroyed), and packaging or containers used to support or carry another product, even if they are reusable. User manuals, labels, catalogues, and marketing materials that come with other products are also not included.
Despite these exclusions, relevant products that are sold as standalone products are still covered by EUDR—meaning multiple products in your portfolio may still be affected. With TRACT, you can manage due diligence for all EUDR-relevant commodities and products.
* The Delegated Act is not in force at the time of writing. It is expected to enter into force the day after its publication in the Official Journal of the EU.
When it comes to legality, self-declarations from producers can be helpful.
The requirement for products to comply with local laws hasn't changed. What's new is that the FAQ recognized producers' self-declarations as helpful to show compliance. However, they’re only supplemental and don’t replace actual proof.
Companies still need to understand local laws and have supporting documents or data. TRACT’s legality framework helps you link that info—whether it's self-declarations, permits, land titles, assessment, contracts, etc.—to farms and supply chains, meaning less work and less risk when audited.
Lawful production is really about the country of production, not countries where manufacturing may have taken place prior to EU import.
The new FAQ clarifies that legality checks should only focus on the country where the product is made, not where any processing happens.
The legality documents on TRACT are smartly linked to country of origin, ensuring you stay focused on the jurisdiction that actually matters.
You can submit Due Diligence Statement annually, but it may not be realistic to do so.
On April 15th, the Commission announced that companies can submit Due Diligence Statements (DDS) once a year instead of for each individual shipment or batch placed on the EU market. This builds on previous FAQ text (from October 2024), which clarified that a DDS can cover multiple shipments as long as it’s within one year from submission.
So this isn’t new—just a clearer statement on existing guidance. In some cases, this may significantly reduce administrative work under EUDR. However, an annual DDS may just be impractical or too risk in many cases:
Liability remains the same: Operators must still ensure all covered products are deforestation-free and legally produced. While this may work for well-established or sustainable supply chains, it’s much harder for indirect or new suppliers, where information essential to due diligence often isn’t available much in advance of the potential shipment.
Annual DDS still requires admin: Declared quantities must match what’s placed on the market, so record-keeping and reconciliation are still needed.
Risk may increase: New risks can emerge during the year, and the FAQ notes that annual DDS adds complexity - something competent authorities may consider when prioritizing checks.
The good news: companies can submit fewer DDS if they complete full due diligence in advance for a defined volume. With TRACT, you auto-generate DDS per shipment, per group, or annually—whatever works best for your supply flow.
If a product is already covered by a DDS and isn’t further processed, a new DDS isn’t needed for resale or export.
The latest FAQ confirms that companies can reuse the DDS reference number from import when selling in the EU or exporting, so long as no additional manufacturing has taken place. This helps reduce the compliance burden by removing the need to submit a new DDS for resale or export.
With TRACT, all reference and verification numbers are automatically linked to shipments, making it easy to keep using the same numbers over time.
EU TRACES remains the official DDS repository and, in line with earlier communication, won’t support collecting or analysing geolocations.
The FAQ reaffirms that the role of the EU Information System is to store due diligence statements—it won’t offer tools to support due diligence itself. That’s where TRACT comes in: it helps you collect geolocations from all suppliers in a consistent format and analyze them using an industry-aligned methodology for assessing deforestation.
The latest FAQ also newly references the Global Forest Map 2020—one of many data layers already integrated into TRACT’s methodology.
Technical limits in the EU Information System remain, restricting both DDS references and file size.
EU TRACES limits each DDS to referencing a maximum of 2,000 other DDS and restricts file uploads to 25MB. This can be a challenge for downstream operators who may need to reference large numbers of upstream DDS. The 25MB cap is especially problematic for real-world shipments involving thousands or millions of farms—particularly when covering multiple batches or shipments.
While the FAQ claims 25MB is enough for 1 million geolocation points, our in-depth testing shows the limit can actually be reached with just 15,000 farms—a common scenario in many supply chains. Staying under this limit often requires data compression or reworking, which takes time, technical expertise, and can compromise accuracy (e.g., reducing complex farm polygons to simple rectangles).
With TRACT, these constraints are no longer a barrier. You can reference unlimited DDS and bypass the 25MB cap—without compromising the precision or integrity of your geolocation data.
Large downstream companies are only required to collect and reference DDS numbers from their suppliers when submitting their own DDS—but many may choose to go further.
For downstream operators, due diligence means checking the due diligence already carried out upstream. This obligation has been clarified and simplified in the latest FAQ. Downstream companies now only need to collect and verify the reference and verification numbers of DDS submitted by their suppliers—without re-checking geolocations or reassessing deforestation-free and legal status.
That said, with your company’s reputation and potential financial penalties at stake, you may want to review your suppliers’ assessments and due diligence processes anyway.
TRACT makes this easy, enabling secure, seamless data sharing across your supply chain.
Stay Ahead of EUDR Changes—Book Your Free Readiness Check Now!
With these updates, now’s the time to ensure your business is fully prepared for EUDR compliance. Schedule a quick conversation with one of our experts who will assess your readiness and guide you on the next steps.
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Looking for More EUDR Resources?
Take your preparation to the next level with these helpful tools:
A Practical Guide to EUDR Legal Due Diligence: A short read on what you need to know about legal requirements and best practices for meeting EUDR standards.
Human Rights Hotspots: Mapping Social Risks in Supply Chains on TRACT: Developed in collaboration with Wageningen University & Research (WUR), helps you ensure both environmental and social compliance while using TRACT’s mapping tools to assess risks in your supply chain.