EUDR Guidance Update: Why End-to-End Traceability Is Central to Compliance

“If a product from a specific location has been determined to meet all EUDR requirements, it's important that the product you physically market in Europe is demonstrably the same product. You must be able to guarantee traceability and that it originates from the same location.” 

• The Netherlands Food and Consumer Product Safety Authority (NVWA) when piloting inspections for the EUDR.

The EU Deforestation Regulation (EUDR) sets a clear expectation for companies: if you are placing relevant products on the EU market, you must demonstrate that they are deforestation-free and legally produced. But meeting this bar isn’t just about box-ticking and passing DDS information downstream - it requires robust, reliable, and auditable end-to-end (E2E) traceability.

Two key areas of the August 2025 EUDR guidance make this especially clear: the due diligence requirements (Articles 8–11) and the criterion of supply chain complexity (Article 10(2)(i)). 

Both reinforce why traceability cannot be partial, fragmented, or stored in filing cabinets. Instead, operators need a connected system capable of following commodities from origin all the way through to the EU market.

Due Diligence Requirements: Why E2E Traceability Matters

Article 8 of the EUDR requires operators to:

• Collect information, documents, and data from each supplier on relevant products (Annex I commodities).
• Verify and analyse this information, alongside contextual risk factors, and carry out a risk assessment (Article 10).
• Adopt risk mitigation measures where risks are not negligible (Article 11).

Put simply, this is not a one-off data collection exercise. It’s an ongoing requirement to prove the origin, legality, and deforestation-free status of every batch of product. Without full traceability, risk assessments quickly become assumptions. Gaps in supplier data or inconsistencies in origin information undermine compliance and expose operators to regulatory and reputational risk.

This is where E2E traceability is non-negotiable. By connecting supplier data across every step of the chain, businesses can ensure they always have the information needed for declarations and risk assessments.

Simplified due diligence - linking points of origin with the importer’s DDS - clearly does not meet the European Commission's expectations of traceability and due diligence. Operators need to know about each step in a supply chain. 

The recent findings of the Dutch Competent Authority’s (the NVWA) test EUDR investigations clearly pointed to shortcomings: 

“During the pilot inspections, it became clear that much of the collected information was not always assessed for risks. Consequently, no actions or measures were linked to this information. This is required by law.” 

How Interu Helps

Interu was built for this challenge. It:

• Collects supplier data securely at each point in the supply chain. 
• Links and verifies that data through third-party verification specialists, making tampering or gaps visible.
• Consolidates information into one view, so operators can demonstrate a defensible due diligence process.

In practice, this means that risk assessments aren’t slowed down by missing documents, untraceable batches, or unverifiable claims. Instead, operators gain a digital backbone of traceability that makes EUDR compliance both efficient and credible.

Complexity of the Supply Chain: A Risk in Itself

The EUDR also recognises that not all supply chains are equal. Article 10(2)(i) lists the “complexity of the relevant supply chain” as a key factor in assessing risk. The reasoning is clear:

• The more processors and intermediaries between the plot of land and the EU market, the greater the risk of losing sight of origin data.
• When commodities from different plots, tree species, or countries are mixed, verifying compliance becomes harder.
• Highly processed or composite products increase the challenge of tracing back to land plots.

In other words, complexity isn’t just an operational headache - it is, by definition, a risk indicator. If operators cannot obtain consistent, accurate data through every step, the risk of non-compliance rises and cannot be considered negligible.

The Role of a Traceability Solution

Interu reduces the compliance burden of complex supply chains by:

• Mapping every step digitally, no matter how many intermediaries or processors are involved.
• Ensuring information travels with the product, preventing data drop-offs or inconsistencies.
• Highlighting gaps automatically, so operators can focus on resolving missing or incomplete information before goods reach the EU.

This transforms complexity from a barrier into something that can be managed with confidence. Operators don’t need to fear long or multi-country supply chains - as long as they are transparent and digitally connected.

The Regulator’s Checklist

In order to assess the complexity of the supply chain, operators and traders may use the following (non-exhaustive) list of questions taken from the EU Guidance document for relevant products to be placed on, or made available on, or exported from the Union market:

1. Were there several processors and/or steps in the supply chain before a particular relevant product was placed on, or made available on, or exported from the Union market?
2. Does the relevant product contain relevant commodities sourced from several plots and/or countries of production?
3. Is the relevant product a highly processed product (which may itself contain multiple other relevant products)?
4. For timber, does the relevant product consist of more than one tree species?
5. Have the timber and/or timber products been traded in more than one country?
6. Were any relevant processed products processed or manufactured in third countries before they were placed on, or made available on or exported from the Union market?

The EUDR doesn’t just ask companies to collect documents - it demands proof of traceability. Both the due diligence requirements and the explicit recognition of supply chain complexity highlight why end-to-end transparency is the foundation of compliance. Without it, risk assessments are incomplete, mitigation measures are unreliable, and compliance claims are fragile.

Interu provides the technology to turn complexity into clarity, helping operators not only meet their obligations but also build trust with customers, partners, and regulators.

Ready to make EUDR compliance simple, reliable, and cost-effective? Request a demo of Interu today and see how end-to-end traceability can work for your business.

Source: EU’s Official EUDR Guidance document 2025

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