SCRM Supplier Compliance & Risk Management

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Regulation (EU) 2023/1115 · application from 30 December 2026

The Deforestation Regulation asks for coordinates. Not for assurances.

For seven commodities and the products made from them, you must evidence the plot they were produced on – at the level of a geolocation, not a country of origin.

The EUDR covers cattle, cocoa, coffee, oil palm, rubber, soy and wood plus many derived products, from chocolate and furniture to tyres and packaging. Placing such goods on the EU market or exporting them requires evidence that they were not produced on land deforested after 2020 and that production complied with the law of the producing country.

After the latest postponement, application starts on 30 December 2026, six months later for small and micro enterprises. The core is unchanged: geolocation of plots, risk assessment, risk mitigation and a due diligence statement in the EU information system.

Who is affected

  • Operators first placing covered goods on the EU market or exporting them.
  • Traders reselling such goods, with obligations graded by company size.
  • Swiss processors and exporters whose products contain cocoa, coffee, wood, rubber or soy and go to the EU.
  • Packaging counts: a pulp-based carton brings an otherwise unaffected product into scope.

Due diligence in three steps

Information
Geolocation of all plots, quantity, producing country, supplier and proof of legality.
Risk assessment
Judge deforestation risk and legal compliance per plot and chain, taking the country benchmark into account.
Risk mitigation
Where risk is more than negligible, additional checks, audits or independent surveys.
Statement
A due diligence statement in the EU information system, linked to the customs declaration.
Retention
Keep records for five years and produce them on request.

How SCRM covers it

Origin down to the plot

Supplier, upstream supplier and place of production as linked records instead of free text.

Evidence with expiry

Legality documents and certificates with validity and reminders.

Documented risk assessment

Assessment per chain, versioned – even a “negligible” rating needs reasoning.

Supplier requests

Surface missing coordinates and chase them specifically.

Frequently asked

We only buy in Europe. Are we affected?

Possibly yes. What matters is the origin of the commodity, not where the supplier sits. Buying through European intermediaries means you need their data on the plot of origin.

Is a certificate such as FSC or Rainforest Alliance enough?

Certificates can support the risk assessment but do not replace it. Geolocation and the due diligence statement remain mandatory.

When should we start?

Data collection is the long part, not the statement. Requesting coordinates in December 2026 will not get them in time.

As of July 2026. The start date has been postponed repeatedly; verify before relying on it. Not legal advice.

Contact

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