The EU Deforestation Regulation (EUDR) — formally Regulation (EU) 2023/1115 — is the most consequential environmental legislation for Latin American exporters in a generation. If your company supplies cocoa, coffee, timber, cattle, palm oil, soy, or rubber to the European market, this regulation is not optional: it carries penalties of up to 4% of annual EU turnover for non-compliance.
This guide covers what EUDR is, who it affects, the actual deadlines after the 2024 extension, and how to structure a due diligence process that passes scrutiny. At the end, we explain how Terralyr's satellite and geospatial technology automates most of this work.
What is EUDR and why does it matter?
EUDR was designed to address the EU's contribution to global tropical deforestation. The European Commission estimates that EU consumption is responsible for roughly 10% of global tropical deforestation through imports of forest-risk commodities. The regulation requires any company placing these commodities on the EU market to prove they were not produced on land deforested after December 31, 2020.
The regulation distinguishes two actor types:
- Operators: companies placing the product on the EU market for the first time. They bear the full due diligence burden.
- Traders: companies buying and reselling in the supply chain. They have reduced obligations but must verify supplier compliance.
The 7 regulated commodities
EUDR applies to these commodities and their derived products:
- 🍫 Cocoa — chocolate, cocoa butter, cocoa powder, paste
- ☕ Coffee — roasted, ground, instant, extracts
- 🐄 Cattle — beef, leather, gelatin, collagen
- 🌴 Palm oil — crude oil, olein, fatty acids, cosmetics
- 🌱 Soy — soy flour, oil, animal feed, tofu
- 🪵 Wood — logs, sawn timber, plywood, paper pulp, furniture
- 🌿 Rubber — natural rubber, tyres, latex gloves
If your product contains any of these as a principal ingredient, you are within EUDR scope.
Who is most affected in Latin America?
The most exposed countries are:
- Brazil: world's largest exporter of soy, beef, and a major cocoa producer. Both the Amazon and the Cerrado biome are under EUDR scrutiny.
- Peru: fast-growing exporter of fine-flavour cocoa and specialty coffee. The Peruvian Amazon has significant deforestation pressure from illegal coca expansion and illegal logging corridors.
- Colombia: premium coffee and cocoa exports largely destined for Europe. Post-conflict zones show recent deforestation patterns that create compliance risk.
- Ecuador: fine-aroma cocoa and banana supply chains with European buyers.
- Paraguay and Argentina: major soy and beef exporters to the EU.
Deadlines: what changed with the 2024 extension?
December 30, 2024: The European Council approved a 12-month extension after significant pressure from exporting countries and industry groups.
The updated deadlines are:
- December 30, 2025: Compliance required for large operators and traders (more than 150 employees or €40M annual turnover).
- June 30, 2026: Compliance required for micro, small, and medium enterprises.
- Start now: Collecting geospatial evidence for production lots from 2021–2023 is time-sensitive. Retroactive evidence collection becomes harder the longer you wait.
The 4-step due diligence process
EUDR mandates a documented due diligence process with four mandatory components:
Step 1: Information collection
For each commodity lot you must collect:
- Geolocation of the production parcel (polygon or GPS coordinate with sufficient precision)
- Country and region of origin
- Date of production or harvest
- Quantity of the commodity
- Supplier or producer data
- Applicable certifications (FSC, Rainforest Alliance, SAN, etc.)
Step 2: Risk assessment
You must assess whether the parcel contains land deforested after December 31, 2020. This requires:
- Satellite forest cover data (Sentinel-2, Landsat, Hansen Global Forest Change)
- Cross-referencing with deforestation databases (PRODES for Brazil, Global Forest Watch, MapBiomas)
- Analysis confirming the parcel was forested before January 1, 2021
Step 3: Risk mitigation
If risk is identified, you must document mitigation measures taken: additional certifications, field audits, supplier substitution, or exclusion of the lot from the EU-bound supply chain.
Step 4: Due diligence statement
Before placing the product on the EU market, you must file a Due Diligence Statement (DDS) in the European Commission's information system (EUDR system replacing TRACES NT). The DDS must reference all collected documents and evidence.
Critical mistakes that cost market access
- ❌ Using point coordinates instead of polygons. EUDR requires the geolocation of the entire parcel (polygon), not just a centre pin, for plots over 4 hectares.
- ❌ Not verifying forest cover on the purchase date. Many producers acquired land recently without checking whether it was forested in 2020.
- ❌ Assuming certifications replace due diligence. FSC and Rainforest Alliance reduce assessed risk but do NOT eliminate the DDS obligation.
- ❌ Failing to document the full chain of custody. If you cannot trace cocoa or coffee from the parcel to the export container, European importers will not accept your DDS.
- ❌ Waiting for the European buyer to request documentation. Penalties fall on the operator (EU importer), who has strong incentives to drop non-compliant suppliers before the deadline.
Geospatial requirements in practice
This is where most exporters get stuck. Article 9 of EUDR states that geolocation must be:
- For plots over 4 hectares: full polygon in GeoJSON or equivalent format
- For plots under 4 hectares: a location point (GPS coordinate)
- Minimum precision: sufficient to determine whether the parcel was forested
The practical problem: the vast majority of smallholder producers in Peru, Colombia, and Brazil have never georeferenced their plots. Collecting this data requires field GPS surveys or high-resolution satellite analysis.
How Terralyr automates EUDR compliance
Terralyr's EUDR module covers all four steps of the due diligence process:
- Automated geolocation: polygon upload in GeoJSON, Shapefile, or KML; offline field GPS capture via the mobile PWA
- Historical forest cover analysis: automatic cross-reference with pre- and post-2020 Sentinel-2 data to determine parcel forest cover
- Per-parcel risk scoring: traffic-light system (green/yellow/red) based on satellite evidence
- Supplier onboarding portal: self-service portal for producers to submit locations and documents
- DDS generation: due diligence statement export in EU-system compatible format
- Batch traceability: linking export lots to origin parcels with full audit trail
📡 Terralyr — EUDR Module
Automate evidence collection, risk assessment, and due diligence statement generation for all 7 regulated commodities. Includes supplier onboarding portal and per-campaign compliance dashboard.
Frequently asked questions
Does EUDR apply to Latin American companies or only to European importers?
Legally, sanctions fall on the EU importer (operator). But in practice, if you cannot provide the documentation that the importer needs for their DDS, they will exclude you from their supply chain. EUDR is indirectly a compliance obligation for every European market supplier.
What if my parcel was deforested before December 31, 2020?
If deforestation occurred before that date, the product is eligible for EU export — provided the full supply chain is traceable. The critical cutoff date is January 1, 2021. If the parcel was forested on December 31, 2020 and deforested afterward, the product is NOT eligible.
Do FSC or Rainforest Alliance certifications replace EUDR due diligence?
No. Certifications are valuable evidence that can lower the assessed risk level, but they do not eliminate the obligation to collect geospatial information and file a DDS. They are complementary, not substitutive.