Regulatory Compliance Brief · EU Deforestation Regulation (2023/1115)
EUDR Compliance —
Where Most Importers Lose Control
In force December 2024. Applies across Africa and Latin America. Brazilian cocoa and soy face identical obligations to Ghanaian or Ivorian shipments.
Compliance isn't the problem. Lack of visibility is.
What the regulation requires
1
File a Due Diligence Statement (DDS) before every shipmentFiled via the EU Information System. Must confirm no deforestation after 31 December 2020.
2
Collect plot-level GPS coordinates from your supplierFor every parcel of land where the commodity was produced. No coordinates = no DDS = no clearance.
3
Maintain records for 5 yearsEvery submission, every document, every supplier confirmation — auditable on demand by competent authorities.
Scope
Covers cocoa, coffee, palm oil, soy, rubber, cattle, timber — and all derived products.
Obligations are identical across origins. Africa and Latin America are treated the same under EUDR. Hundreds of HS codes fall within these 7 commodity groups — if your product is derived from any of the above, it is in scope regardless of processing level.
The two obligations that trip importers
📍 Geolocation data from your supplier
Plot-level GPS coordinates for every production area. For smallholder aggregation, mass balance geolocation is accepted under specific conditions.
Without this, your shipment will not clear.
📋 Due Diligence Statement submission
Filed via the EU Information System before shipment entry. Must include commodity, HS code, quantity, country of production, geolocation, and supplier details.
One error and the system rejects it.
Penalty framework
| Violation | Maximum penalty | Additional consequence |
|---|---|---|
| Placing non-compliant goods on EU market | 4% of EU annual turnover | Shipment seizure and disposal at importer cost |
| Incomplete or false DDS submission | Proportional fine | Temporary ban from EU market access |
| Failure to maintain 5-year records | Administrative penalty | Enhanced audit obligation |
Without CouloirIQ — what this looks like in practice
1
Supplier confusion — 2 weeks lost. You email your supplier in Côte d'Ivoire asking for GPS coordinates of the cocoa farm. They don't know what you mean. Two weeks of back-and-forth while the loading window closes.
2
DDS rejected — shipment held. You manually compile the Due Diligence Statement. One field wrong — the EU Information System rejects it. The shipment sits at Rotterdam while you correct and resubmit. Demurrage running the whole time.
3
No audit trail — full exposure. Customs queries the shipment 8 months later. You have no record of what was submitted, when, or by whom. You cannot prove compliance.
