EUDR: Compliance Flow - A Step-by-Step Guide

The first step in your compliance journey is ensuring your system contains accurate and up-to-date information. You need to upload all relevant supplier and product data into your environment.

You can choose the method that best fits your workflow:

Before launching your Product Origin Requests, we recommend conducting an introductory email campaign to your supplier network. By notifying your partners in advance that you work with the Prewave platform, you ensure they recognize and prioritize our outreach as a trusted extension of your business.

This proactive step helps to increase initial response rates but also serves as a vital diagnostic tool. By identifying bounced emails or outdated contacts during this preliminary phase, you can secure the correct stakeholder information.

Once your data is successfully set up, you can begin the active compliance phase. The first action is to send a Product Origin Request to your supplier. Through this request, suppliers can provide precise details regarding product origin and producer information, alongside necessary due diligence statement references and verification numbers. Additionally, if a product falls outside the scope of current regulations, suppliers have the option to declare it as non-EUDR relevant by uploading the specific supporting evidence directly to the platform. The supplier's response to this request determines the specific path your product will follow in the compliance flow.
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Depending on the feedback provided by your supplier, your product will fall into one of the following categories:

The supplier has provided the necessary documentation or data points to move the compliance process forward. In this scenario, the supplier may share an existing Due Diligence Statement (DDS), confirming that due diligence has already been exercised. The supplier has also the opportunity to submit a One-Time Declaration if this applicable to them according to the law. These statements are then stored under the Supplier DDS section, requiring no further assessment.

Alternatively, the supplier may provide specific Origin Information, such as geolocation data.

The subsequent workflow is then determined by the EU Benchmarking risk level of the country of origin: for Low Risk regions, you may proceed directly to DDS generation without further deforestation or legality assessments, whereas Standard or High Risk regions will require mandatory assessments in Step 4.

If the supplier indicates the product is not subject to EUDR, a "Rejected" status is returned. A product may be classified as non-EUDR relevant if it meets specific exemption criteria defined by the European Commission. This includes products manufactured entirely from recycled materials, product that are not concerned by the regulation due to its composition (e.g. synthetic rubber, bamboo, rattan), those produced prior to June 20, 2023, products delivered by a micro- or small-sized undertaking or items placed on the EU market during the official transitional period (conventional DDS reference number 99EU9999999999). If a product falls outside the regulation's scope for these reasons, suppliers can declare the exemption by providing the necessary supporting evidence directly through the platform. Products out of scope don't require further assessments.

If a supplier is not yet in a position to fulfill a request, they can select the Data Pending status to provide transparency on the delay. This option is available for several common scenarios, such as awaiting data from upstream partners, managing high product complexity, or cases where a legally binding Due Diligence Statement (DDS) is not intended before 2027.

To ensure your compliance timeline remains on track, the supplier must then indicate an expected delivery date for the missing information. The request will remain open in the system until that date, allowing for clear tracking and follow-up.

For products sourced from standard or high-risk countries, you must complete two assessments - the deforestation assessment (also known as deforestation check) as well as the legality assessment.

The deforestation assessment checks the risk of deforestation at the product’s origin. It evaluates geolocation data to determine whether the product comes from an area at risk of deforestation. If the first check (basic check) detected deforestation, non-negligible risk, an advanced deforestation check can be conducted (Note: Advanced checks by Satelligence are a contractual feature. If you do not have these included in your current contract, please reach out to your Account Executive to discuss an update).

If the assessment results in a Green Dot (negligible risk), the product can move forward in the compliance process. If it remains non-negligible, the product is considered non-compliant and cannot be placed on / imported in the European market.

This assessment ensures that the product complies with EUDR's legality requirements, including the legal harvesting of raw materials.
The platform checks the producer’s country risk and industry risk based on external data sources. If the score is 40 or above, the product is considered compliant and is cleared for the next step. If the score remains below 40, the process is blocked and a DDS can not be generated.

The EUDR Perspective is the basis for the risk score.