The Dutch competent authority for the EUDR, the Netherlands Food and Consumer Product Safety Authority (NVWA), recently conducted pilot inspections on 25 companies across six out of the seven EUDR commodities (except timber).

The results are telling: Only 40% of the inspected companies complied with the EUDR requirements.

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The following key insights resulted from these 'dry runs':

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Due diligence goes beyond gathering information

Collecting data under Articles 9 and 10 is only the first step of EUDR due diligence. Companies must also evaluate and assess risks based on that information.

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Platforms can support but not replace due diligence

Software platforms can support information gathering and risk assessment, but you must assess and weigh risks within your company. Your company remains responsible for conducting due diligence; a platform cannot replace it.

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Certification does not replace due diligence

Certification alone does not fulfill due diligence obligations. It can serve as a risk mitigation measure provided you clearly understand which risks it addresses.

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Due diligence works better as a fixed part of business operations

Due diligence systems integrated into daily business operations, such as purchasing, sales, and inventory administration, perform better than systems that operate independently.

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Due diligence is required for all requested topics

Certain sectors already have extensive experience conducting due diligence on issues specific to their industry, such as human rights or deforestation. For the EUDR, you are expected to give sufficient attention to all requested topics; your previous work can help you with this.

For example, identify and mitigate risks at processing areas, including reducing the risk of mixing with products of unknown or deforested origin.

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Linking the physical product to its location of origin

If a product from a specific location has been determined to meet all EUDR requirements, you need to demonstrate that the product you physically market in Europe is the same product. You must be able to guarantee traceability and that it originates from the same location. We've seen that most companies have been able to source products from deforestation-free locations.

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