From EUDR readiness to EUDR reality: five key takeaways from our recent webinar

cover image EUDR webinar

Associate Director

United Kingdom

EMEA Nature Lead

Spain

giacomo ranalli

Giacomo Ranalli

Senior Consultant – Sustainable Agrifood

With the EU Deforestation Regulation (EUDR) applying to large and medium-sized companies from 30 December 2026, many businesses have completed their readiness assessments. Now they face a harder question: how do we actually implement EUDR across our supply chains?

That was the focus of our recent webinar, From EUDR Readiness to EUDR Reality: Navigating the Implementation Challenge. Liudmila Chambers, Giacomo Ranalli and Victor Fábrega from Anthesis were joined by Alberta Zatta and Tim Kuhn from our technology partner LiveEO. Here are five key takeaways.

1. Your real deadline is earlier than 30 December

The regulation applies from 30 December 2026 for large and medium-sized companies, and from 30 June 2027 for micro and small companies. A delegated act published in September 2026 also updated the product scope: products newly added under the revised HS codes have until 30 December 2027.

For many businesses, however, the real deadline is already here. Goods entering the EU in early 2027 are being sourced, produced and shipped now, and container journeys can take weeks or even months. Readiness needs to be in place before shipment, while there is still time to resolve any issues.

The goal for the coming weeks is not perfection, but minimum viable readiness. We recommend that companies prioritise six steps:

  1. Confirm scope, roles and legal entities. 
  2. Map and prioritise suppliers by risk and volume. 
  3. Set governance and risk acceptance criteria. 
  4. Engage suppliers and validate geolocation and legality data. 
  5. Confirm your technology approach. 
  6. Test your due diligence statement workflow before December. 

            Full coverage and automation can then follow during 2027. 

            2. Implementation timelines depend on more than supply chain complexity

            The question we hear most often is: “How long will it take us to be ready?” The honest answer is that it depends. 

            A company with a handful of direct suppliers in low-risk countries and existing traceability may need only a few weeks. A company sourcing from hundreds or thousands of suppliers across multiple tiers, covering tens of thousands of plots of land, could be looking at several months. 

            Supply chain complexity is only part of the picture. Timelines also depend on: 

            • Supplier readiness: whether someone at each supplier clearly owns EUDR and can respond on time.
            • Internal governance: how responsibility is divided within your own organisation.
            • Data quality: how complete supplier data is, and how much validation it needs.
            • Remediation: the work required once gaps are identified. Finding a gap is quick; re-engaging a supplier and correcting plot data can take much longer.

            Most of the challenges that emerge during implementation are operational. Suppliers may not hold the information required under Article 9, or may send geolocation data for the wrong country. Some will only share data once a commercial commitment is confirmed, or after shipment. Grey areas in the guidance, and customers asking for evidence beyond the legal requirements, add further complexity. All of these issues can be resolved, but they take time. 

            3. Technology is essential, but it can’t make your decisions for you

            For complex supply chains, a digital platform is indispensable. Tools such as LiveEO’s TradeAware support supplier engagement, data collection, satellite-based deforestation risk assessment and the generation of due diligence statements.

            Our partnership with LiveEO is part of Anthesis Intelligence, our digital ecosystem, which brings together specialist technologies for supply chain data collection, carbon footprinting, product LCA, reporting and disclosure, and climate risk. Our aim is to pair deep subject-matter expertise with best-in-class technology, so that the solutions we implement with clients are tailored, scalable and fit for purpose.

            However, a platform alone won’t close data gaps or resolve non-compliance; it is only as good as the human judgement behind it. Operators remain legally responsible, so companies need clear, documented answers to questions such as:

            • What counts as negligible risk?
            • When is evidence sufficient?
            • What do we do when evidence is contradictory? 

            The regulation doesn’t set a universal threshold for negligible risk, so many companies default to a simple pass/fail model. In practice, this tends to be either too permissive, letting weak evidence through, or too restrictive, excluding suppliers who could qualify with more support.

            Instead, we recommend a progressive, risk-based framework in which the evidence you require reflects the level of risk. A coffee lot from a low-risk country with high-quality plot data shouldn’t need the same evidence as cattle from a high-risk region with indirect suppliers. This approach leads to consistent, auditable decisions that become stronger as your data improves.

            4. Don’t take open datasets at face value 

            Public datasets are a useful starting point, but relying on them alone can create a great deal of unnecessary work.

            LiveEO shared a benchmarking exercise comparing the EU’s Global Forest Cover (GFC) map with its own satellite-based analysis of plots uploaded by customers in 2025. The results were striking:

            • Cocoa: almost every plot was flagged by the GFC as a deforestation risk, possibly because of agroforestry practices. 
            • Timber: for every 1,000 plots, the GFC flagged around 969, while LiveEO’s analysis flagged around 68. In other words, around 93% of the GFC’s flags were incorrect. 
            • False negatives: cases where the GFC missed deforestation that LiveEO identified were rare, affecting fewer than 1% of plots. 

            The EU has made clear that the GFC is neither mandatory nor exclusive, and has no legal status. However, competent authorities have referred to it in dry-run audits, so if a plot overlaps with a GFC flag, you should be able to explain why it is a false positive.

            The most robust approach, and the one competent authorities are expected to take, is to review satellite imagery of the actual land use at the 31 December 2020 cut-off date, then assess what has changed since. Doing this manually is time-consuming and resource-intensive, particularly for organisations with large numbers of sourcing locations. Automated, large-scale satellite analysis, such as that provided by TradeAware, makes these assessments faster and more consistent while reducing the burden of manual review.

            5. Get the operational fundamentals right

            Some of the most valuable insights from the Q&A were practical:

            • Appoint one owner. EUDR spans procurement, sustainability, legal and IT teams that may not usually work closely together. Give it a single owner, supported by a cross-functional team, a clear RACI matrix and documented processes for difficult cases. 
            • Prioritise suppliers strategically. Start with the suppliers you most need in place from January, not simply the largest by volume, and consider whether alternatives exist. 
            • Help suppliers understand why. EUDR isn’t a requirement you are imposing: it applies to everyone trading in the EU market, so suppliers are likely to receive the same request from other customers. 
            • Verify data early. For example, check that suppliers claiming low-risk origins really are sourcing from those countries, as this determines whether simplified or full due diligence applies. If you correct supplier data yourself, let the supplier know and give them the chance to validate the changes. 
            • Check what is in scope. Products made entirely from recycled or synthetic materials may fall outside the scope of the regulation, even if their HS code matches. Note that certifications using a mass balance approach are not recognised as evidence of EUDR compliance, although other criteria within those schemes may support your risk assessment. 
            • Use TRACES grouping with care. This feature is designed for GeoJSON files larger than 25 MB. Once due diligence statements are grouped, the originals are revoked and can’t be regrouped. Unless your files exceed the limit, submitting separate statements is usually the safer option.

            Moving from readiness to reality 

            Compliance isn’t about achieving perfection on day one. It’s about making decisions you can explain, document and stand behind, then refining them as your data and experience grow. 

            Anthesis combines regulatory expertise, hands-on implementation support and technology through Anthesis Intelligence, including our partnership with LiveEO. Together, these help companies implement EUDR due diligence efficiently, consistently and with confidence. 

            Watch the webinar recording or get in touch via [email protected] to discuss your EUDR implementation. 

            We are the world’s leading purpose driven, digitally enabled, science-based activator. And always welcome inquiries and partnerships to drive positive change together.

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