When will the EUDR apply to your company?

From 30 December 2026 for large and medium-sized companies and from 30 June 2027 for micro and small enterprises. The one-year postponement really is a postponement, not a cancellation: the date is fixed, although the European Commission still has to carry out a simplification review by 30 April 2026 at the latest, as a result of which details may change.

Which products fall under the EUDR?

Seven commodities and their derived products: cattle, cocoa, coffee, palm oil, rubber, soya and wood, and therefore also end products such as chocolate and processed meat. If you process such commodities or place them on the EU market, you fall within its scope.

What must you be able to show for each shipment?

That the commodity does not come from land deforested after 31 December 2020, with the geographical coordinates of the plots of land. In addition, for each shipment you submit a due diligence statement through the EUDR system in TRACES and keep the reference number and the underlying information for at least five years.

What can AI take over in EUDR due diligence?

AI tools validate geodata, compare satellite images with the cut-off date of 31 December 2020 and help prepare the risk assessment and the due diligence statement (DDS). The conclusion that a batch carries negligible risk remains your decision and your signature.

FoodPublished 14 July 20264 min read

EUDR from 30 December 2026: making due diligence for cocoa, coffee and soya in food manageable with AI

Short answer

The EUDR (EU Deforestation Regulation) applies from 30 December 2026 to large and medium-sized companies and from 30 June 2027 to micro and small enterprises. For each shipment, you show that the commodity does not come from land deforested after 31 December 2020, with geolocation and a due diligence statement in TRACES. AI prepares, you sign.

After a one-year postponement, the EU Deforestation Regulation (EUDR, Regulation (EU) 2023/1115) will apply from 30 December 2026 to large and medium-sized companies, and from 30 June 2027 to micro and small enterprises (European Commission). For food producers working with cocoa, coffee, soya, palm oil or cattle products, that means a specific obligation: for every batch you must be able to show that the commodity does not come from land deforested after 31 December 2020, with geolocation of the plots of land and a due diligence statement for each shipment. For many SMEs, that is almost impossible to do by hand. In that context, AI is being offered as a solution. This article gives an honest account of what the law requires, what AI does and does not take over, and how to start without compliance swallowing up your entire purchasing department.

On this page

What the EUDR requires of a food producer in practice
Postponed is not cancelled, and the rules may still change
Where AI makes the work manageable
Be critical of tools, and measure process by process
The human decides, and must understand the AI
Where to start in practice

What the EUDR requires of a food producer in practice

The EUDR applies to seven commodities and their derived products: cattle, cocoa, coffee, palm oil, rubber, soya and wood, and therefore also to end products such as chocolate and processed meat (European Commission). If you process such commodities or place them on the EU market, you must show through due diligence that they do not come from land deforested after 31 December 2020. That requires collecting the geographical coordinates of the plots of land the commodity comes from.

Next, for each shipment you must submit a due diligence statement (DDS) through the EUDR system in TRACES; you must keep the reference number and the underlying information for at least five years (NVWA, the Netherlands Food and Consumer Product Safety Authority). In the Netherlands, the NVWA is the supervisory authority that enforces this through checks on importing, producing and exporting companies. This is not without consequences: in the event of non-compliance, fines of at least 4 percent of total annual EU turnover can be imposed and products can be confiscated (Coolset, based on Article 25 EUDR).

Postponed is not cancelled, and the rules may still change

The postponement to 30 December 2026 is laid down in amending Regulation (EU) 2025/2650, which was published on 23 December 2025 and entered into force on 26 December 2025 (European Commission). So it really is a postponement, not a cancellation: the obligation is coming, and the date is fixed.

At the same time, it is only right to be honest about the uncertainty. The same regulation requires the European Commission to carry out a simplification review of the EUDR by 30 April 2026 at the latest, with a legislative proposal if necessary. Details of the implementation may therefore still change. That is no reason to wait, but it is a reason to set up your approach so that you are not locked into an expensive, rigid solution before the picture is fully clear.

Where AI makes the work manageable

The burden of the EUDR lies not in understanding the rule but in the volume and origin of the data: geolocation for each plot, a check on whether deforestation took place there after 2020, and a substantiated risk assessment for each shipment. That is exactly the kind of repetitive, data-intensive work where AI can make a difference.

AI tools for the EUDR validate geodata, compare satellite images with the situation on the cut-off date of 31 December 2020 to determine whether forest was present, and help prepare the risk assessment and the DDS. That considerably reduces the manual work. What it does not do is take over responsibility: the conclusion that a batch carries negligible risk remains your decision and your signature, even if a model supplied the supporting evidence.

Be critical of tools, and measure process by process

A market of compliance vendors has emerged around the EUDR, from specialised platforms to modules in existing software. The quality and the fit with your own supply chain vary greatly. So ask a vendor for a trial with your own commodity flows and suppliers, not for a generic time-saving percentage from a sales pitch.

First establish which of your commodities fall under the EUDR, how many suppliers and plots they come from, and how you currently obtain origin information. That is your baseline measurement. Only then can you judge whether an AI tool makes the difference between workable and unworkable EUDR paperwork, and whether the investment is justified by the risk of a lost delivery or a fine.

The human decides, and must understand the AI

A DDS with a score of negligible risk is a legal statement for which you are held to account. An AI that validates geodata and estimates risk is a tool you must be able to check, not a black box you sign off blindly. Good tools show what a risk estimate is based on, so that your quality or purchasing manager takes a well-founded decision.

In addition, Article 4 of the EU AI Act has applied since 2 February 2025, and since 27 July 2026 it has asked providers and deployers for measures that support the AI literacy of their staff, without requiring them to guarantee a specific level (Regulation (EU) 2026/1744). For the EUDR, what matters in practice is that the people who work with such a tool understand how the risk assessment is arrived at and when they need to intervene manually. That way, compliance remains yours and not the software's.

Where to start in practice

Start with an inventory rather than a tool. Which of your products contain EUDR commodities, which suppliers are behind them, and what origin information do you already receive? Then choose the commodity with the most suppliers or the highest risk and try to gather the required geolocation and supporting evidence for that flow. That shows you straight away where the bottlenecks are.

Our free Practice Scan helps you choose that first commodity flow and determine which data you are missing, so that any investment in AI-driven traceability is based on your own supply chain and the actual EUDR requirements, not on a vendor's promise.

Sources

Frequently asked questions

When will the EUDR apply to your company?: From 30 December 2026 for large and medium-sized companies and from 30 June 2027 for micro and small enterprises. The one-year postponement really is a postponement, not a cancellation: the date is fixed, although the European Commission still has to carry out a simplification review by 30 April 2026 at the latest, as a result of which details may change.
Which products fall under the EUDR?: Seven commodities and their derived products: cattle, cocoa, coffee, palm oil, rubber, soya and wood, and therefore also end products such as chocolate and processed meat. If you process such commodities or place them on the EU market, you fall within its scope.
What must you be able to show for each shipment?: That the commodity does not come from land deforested after 31 December 2020, with the geographical coordinates of the plots of land. In addition, for each shipment you submit a due diligence statement through the EUDR system in TRACES and keep the reference number and the underlying information for at least five years.
What can AI take over in EUDR due diligence?: AI tools validate geodata, compare satellite images with the cut-off date of 31 December 2020 and help prepare the risk assessment and the due diligence statement (DDS). The conclusion that a batch carries negligible risk remains your decision and your signature.

This article is for information only and is not legal advice. Market prices and schemes mentioned are indications as of the publication date; check current conditions with the official sources. Translated from the Dutch original.