The EU Deforestation Regulation is now one of the most operationally significant pieces of environmental legislation affecting food supply chains in Europe. For food businesses sourcing beef, cocoa, coffee, palm oil, or soy—directly or as ingredients in processed products—it requires active preparation before the December 2026 enforcement deadline.
This guide covers what EUDR requires, which food businesses are in scope, how it connects to Scope 3 emissions reporting, and why the data infrastructure for compliance and carbon accounting overlaps significantly.
The EU Deforestation Regulation (EUDR), Regulation (EU) 2023/1115 as amended by Regulation (EU) 2025/2650, prohibits placing products on the EU market if they are linked to deforestation or forest degradation after December 31, 2020.
The regulation's core requirement is simple in principle: businesses must demonstrate that the commodities in their products were not grown on land that was deforested or degraded after the December 2020 cutoff. In practice, that requires traceability to specific production plots, geolocation data, and documented evidence of legal production in the country of origin.
Following a second delay adopted in December 2025, large and medium operators must comply from December 30, 2026. Small operators—defined as businesses with fewer than 50 employees and annual turnover below €10 million in relevant products—have until June 30, 2027.
December 2025 amendments also simplified certain requirements: only the first operator placing a relevant product on the EU market is now required to submit a full Due Diligence Statement (DDS) to the EU IT system. Downstream operators must retain due diligence records for audit purposes but no longer file separate statements.
EUDR targets seven commodity categories and their derived products:
Cattle—beef, leather, live cattle, and products containing beef-derived ingredients
Cocoa—chocolate, cocoa powder, cocoa butter, and food products containing cocoa
Coffee—roasted and unroasted coffee, coffee extracts, and derived products
Palm oil—palm oil, palm kernel oil, glycerol, and products containing these as ingredients
Soy—soybeans, soybean oil, soybean flour, tofu, and animal feed derived from soy
Rubber—natural rubber and rubber products (less commonly relevant to food businesses)
Wood—timber, pulp, paper, and printed products (printed products were removed from scope in the December 2025 amendments)
For food businesses, the practical scope is concentrated in the first five categories. A hotel group, contract caterer, or food producer sourcing any of these ingredients, or purchasing processed food products that contain them, is directly affected.
For operators placing covered products on the EU market, EUDR compliance requires three things:
Businesses must know precisely where the commodity was produced—not just the country of origin, but geolocation coordinates tied to specific plots of land where the commodity was grown or raised. This is the most operationally demanding requirement for most food supply chains, where sourcing records rarely include plot-level data.
The production plots must be shown not to have contributed to deforestation or forest degradation after December 31, 2020. The EU benchmarks countries by risk level (high, standard, or low risk), which affects the level of due diligence required. Products from low-risk countries face simplified requirements; high-risk origins require more extensive verification.
Products must have been produced in compliance with the laws of the country of origin, covering land rights, environmental regulations, and labor standards.
For large operators importing in-scope commodities, this means building or sourcing a traceability system capable of capturing and maintaining plot-level supply chain data at scale—something that cannot be managed reliably in spreadsheets given the volume of suppliers and SKUs involved.
EUDR and Scope 3 emissions reporting are distinct obligations with separate data requirements, but they draw on overlapping information about food supply chains. Understanding where they connect is useful for businesses managing both simultaneously.
The seven EUDR commodities—cattle, cocoa, coffee, palm oil, soy, rubber, and wood—are also the ingredient categories with the highest land-use-related emissions in the food system. Under the SBTi FLAG framework (Forest, Land, and Agriculture), food businesses must report and set targets specifically for land-use-linked emissions. These emissions sit predominantly in the same ingredient categories that EUDR covers.
EUDR requires plot-level geolocation data; Scope 3 Category 1 reporting and FLAG emissions calculation are significantly more accurate with country- and region-of-origin data. Both obligations push food businesses toward more granular supply chain traceability. Building the infrastructure to track ingredient origins at scale serves both purposes.
Activity-based Scope 3 Category 1 calculation requires SKU-level procurement data—what was bought, in what quantities, from which suppliers. EUDR compliance requires similarly granular records of what was sourced, where it came from, and what documentation supports its deforestation-free status. A food business investing in procurement data systems for carbon reporting is building infrastructure that also supports EUDR due diligence processes. For a guide to building that data foundation, see Sustainability Reporting for Food Businesses.
CSRD's ESRS E1 standard requires emissions disclosures including Scope 3; ESRS E4 covers biodiversity and ecosystems, with deforestation-linked supply chain risks directly relevant. Food businesses managing EUDR compliance will be generating supply chain data that also informs CSRD's nature-related disclosure requirements.
For a full guide to FLAG emissions and how they apply to food businesses, see FLAG Emissions: A Complete Guide for Food Businesses. For a full breakdown of CSRD obligations for food businesses, see How to Prepare CSRD Reporting for Food Businesses.
It's worth being precise about what EUDR compliance involves versus what food emissions reporting involves, because they are different processes.
EUDR requires geolocation data, legal documentation, and Due Diligence Statement submissions to the EU's regulatory IT system. That is a supply chain traceability and compliance process, and dedicated EUDR compliance platforms are built specifically to manage it.
Klimato Food Emissions handles the emissions calculation layer: mapping procurement data to ingredient-level emission factors, covering FLAG land-use emissions, and producing CSRD-ready Scope 3 Category 1 reporting. It does not replace a dedicated EUDR compliance tool, but it provides the origin-specific, FLAG-inclusive emissions data that food businesses need alongside their EUDR traceability work.
For food businesses managing both obligations simultaneously, the practical implication is this: the SKU-level procurement data, origin information, and supplier engagement processes that EUDR requires are the same data that activity-based Scope 3 Category 1 reporting depends on. Investing in that data infrastructure once, managed centrally, is significantly more efficient than running parallel processes for compliance and carbon reporting separately.
For more on how Scope 3 Category 1 reporting works for food businesses, see Scope 3 Category 1: The Food Business Guide.
Large contract caterers and food service operators sourcing beef, dairy, coffee, or products containing palm oil or soy are directly affected if they place products on the EU market or source from operators who do. Many will be downstream operators under the December 2025 amendments—meaning their immediate compliance obligation is record-keeping rather than DDS submission—but this requires knowing which of their suppliers are primary operators and ensuring those suppliers are compliant.
Hotel groups and hospitality businesses with significant F&B operations sourcing from the covered commodity categories need to map their ingredient supply chains against EUDR scope and establish which suppliers are responsible for due diligence submissions.
Food producers and manufacturers using cocoa, coffee, palm oil, or soy as ingredients in products sold on the EU market are likely to be primary operators, meaning full DDS submission requirements apply from December 2026.
Wholesalers and distributors handling covered commodities or products containing them need clarity on where they sit in the supply chain relative to the first-operator definition, which determines their specific due diligence obligations.
For all of these businesses, the December 2026 deadline is close enough that preparation should already be underway, particularly given the lead time required to build plot-level traceability for complex, multi-origin supply chains. For a practical guide to engaging food suppliers for emissions and traceability data, see Scope 3 Supplier Engagement for Food Businesses.
Q: What is the EUDR and why does it matter for food businesses?
A: The EU Deforestation Regulation (EUDR) requires businesses placing products on the EU market to prove that the commodities in those products were not produced on deforested land after December 31, 2020. For food businesses, the relevant commodities are cattle (beef), cocoa, coffee, palm oil, and soy—ingredients that appear across a wide range of food products. Large and medium operators must comply from December 30, 2026; small operators from June 30, 2027.
Q: Which food products are in scope for EUDR?
A: Any food product containing cattle, cocoa, coffee, palm oil, or soy—including processed products where these appear as ingredients—may be in scope. Chocolate, beef products, coffee, palm oil derivatives used in food manufacturing, tofu, and soy-based sauces are among the most commonly affected categories for food businesses.
Q: What does EUDR compliance actually require?
A: Compliance requires traceability to the specific plots of land where covered commodities were produced, geolocation data for those plots, evidence that the land was not deforested after December 31, 2020, and documentation of legal production in the country of origin. For operators placing products on the EU market for the first time, this means submitting a Due Diligence Statement to the EU's regulatory IT system.
Q: How does EUDR connect to Scope 3 emissions reporting?
A: Both EUDR and Scope 3 Category 1 reporting require granular knowledge of what was sourced and where it came from. The commodities covered by EUDR—particularly cattle, soy, and palm oil—are also the ingredients with the highest land-use-related emissions under the SBTi FLAG framework. Building origin-specific supply chain traceability for EUDR also strengthens the data foundation for ingredient-level Scope 3 Category 1 and FLAG emissions reporting.
Q: Is Klimato a EUDR compliance tool?
A: Klimato Food Emissions handles the emissions calculation layer—mapping procurement data to ingredient-level emission factors, covering FLAG land-use emissions, and producing CSRD-ready Scope 3 Category 1 outputs. EUDR compliance requires specific geolocation data and Due Diligence Statement submissions, which are managed through dedicated supply chain traceability platforms. The two processes share a common data foundation—origin-specific procurement records—but serve different regulatory purposes.
Q: What should food businesses be doing now to prepare for EUDR?
A: Map which commodities in your supply chain fall within EUDR scope. Identify which of your suppliers are primary operators under the regulation—those placing covered products on the EU market for the first time—since they bear the primary DDS submission obligation. Assess whether your current procurement records provide sufficient origin data to support traceability requirements, and begin supplier engagement on EUDR readiness for your highest-risk commodity categories.
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Klimato Food Emissions calculates ingredient-level FLAG emissions—the land-use and agriculture impact embedded in your food procurement—alongside full Scope 3 Category 1 reporting, aligned with CSRD and SBTi.