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Introduction: Why procurement is key to EUDR compliance

The EU Deforestation Regulation (EUDR) is a sweeping new law designed to keep deforestation-linked products out of the EU market. It requires companies to prove that certain commodities, including coffee, cocoa, palm oil, soy, wood, cattle, and rubber, are both deforestation-free and legally produced. In practice, this means companies must trace these products back to the specific plot of land where they were produced and confirm that no deforestation occurred after December 2020, and that all relevant local laws were followed.

While many EUDR discussions focus on sustainability or legal departments, procurement is where compliance truly begins. Procurement and supply chain teams are responsible for onboarding suppliers, collecting sourcing data, and making purchasing decisions, actions that directly determine whether EUDR requirements can be met. If a procurement process fails to gather the right supplier data or overlooks a high-risk origin, the company cannot demonstrate compliance.

Procurement is the first and most critical link in the EUDR compliance chain. From the moment a supplier enters the picture, procurement teams must be equipped to ask the right questions, assess deforestation and legality risks, and ensure that all necessary information is captured as part of the sourcing process.

EUDR compliance is also ongoing. Procurement workflows must continuously support activities like updating supplier information, monitoring for changes in risk, and ensuring each shipment has the proper due diligence statement. This article outlines how to operationalize EUDR compliance inside your procurement process, stage by stage, so that it becomes a seamless part of supplier management.

EUDR requirements that impact procurement

To comply with EUDR, companies must collect detailed information, assess deforestation and legality risks, and ensure that every shipment of in-scope commodities meets regulatory standards. Several of these obligations fall directly on procurement:

Geolocation to the plot level

Procurement must obtain the exact GPS coordinates of the land where the commodity was produced, not just the region or supplier name. Suppliers must provide this data before contracts are signed. If they cannot, they likely are not viable partners under EUDR.

Proof of legality and deforestation-free status

Suppliers must provide documentation showing the product was harvested legally and in line with all relevant local laws, such as land use permits, harvest licenses, or sustainability certifications. Procurement teams should clarify early in the engagement that this documentation is a condition of doing business and embed these requirements into contract negotiations and onboarding.

Country risk classification

EUDR introduces a benchmark system that classifies countries as low, standard, or high risk for deforestation. Sourcing from standard or high-risk areas is not prohibited, but it does require deeper scrutiny. Procurement must factor country risk into supplier selection and ensure additional documentation or mitigation measures are in place when sourcing from standard- or high-risk regions.

Due Diligence Statements (DDS)

Every shipment must be linked to a DDS submitted in the EU’s TRACES system. Procurement, logistics, and operations teams must coordinate to ensure that no shipment moves without a corresponding DDS reference, just like a packing list or customs form. Tracking DDS numbers should become a routine part of purchase and delivery workflows.

Procurement is the operational engine of EUDR compliance. The data, documents, and checks needed to fulfill legal duties must be built into how suppliers are selected, contracted, and managed from the start.

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Step-by-step: embedding EUDR into your procurement process

The best way to implement EUDR is by aligning its requirements with your existing supplier lifecycle. Instead of treating compliance as an extra burden, build it into how you already select, contract, and manage vendors.

Pre-screening and supplier selection

Start by filtering out suppliers who cannot meet EUDR requirements before you invest time or risk non-compliance later.

• Assess country and commodity risk: Identify the product’s origin and check its country risk classification (low, standard, high) under EUDR. Many companies now factor risk levels into their sourcing strategy or vendor preferences.
  
• Ask EUDR questions in RFIs/RFQs: Embed key EUDR criteria into early supplier questionnaires. Can the supplier provide geolocation? Do they have proof of legality, certifications, or traceability systems? If they cannot answer clearly, that is a red flag. If they already track this data, that signals readiness.
  
• Evaluate transparency and readiness: Gauge how organized and forthcoming suppliers are. Ask for sample coordinates or traceability reports. Suppliers without visibility into their own sources may struggle to comply. Make EUDR capability part of your selection scorecard.

Contracting and onboarding

Once a supplier is selected, set the right legal and operational expectations from the start.

• Include EUDR clauses in contracts: Add contract language requiring suppliers to guarantee their products are deforestation-free and legally produced, and that they will provide the data needed for EUDR compliance. This gives you legal grounds to request documents or audits if needed.
  
• Collect data during onboarding: Use onboarding forms or supplier portals to collect required data. Build this into your existing onboarding flow so the supplier is fully set up for compliance from day one.
  
• Set the tone early: Explain that EUDR data is not optional. It is a condition of doing business. Share a one-pager or checklist of what you will need per shipment so the supplier knows what is coming. Clear communication now avoids friction later.

Purchase order and shipment workflows

EUDR due diligence continues for each shipment. Procurement and operations must embed compliance into purchasing and logistics.

• Link orders to due diligence records: Each purchase order should be linked to verified supplier data, GPS coordinates, documents, and risk assessments and mitigations. Use batch numbers or internal codes to keep this information traceable and accessible before goods ship.
  
• Two DDS processes: import and market placement: Every shipment of in-scope commodities must be covered by a DDS. This can happen at different stages depending on your role in the supply chain.
  

• If importing a regulated raw material (like leather), you are the operator at the border and must submit a full DDS before the goods enter the EU.
• If sourcing that material from within the EU (e.g., buying EU-imported leather to manufacture handbags), you become the operator at the point of sale and must submit a DDS before placing the final product on the EU market.
  

• Coordination across teams: Procurement, logistics, and compliance must collaborate across the full process.From supplier engagement and data collection, to compliance checks, to ensuring that logistics and operations teams have the right information to communicate with customers.

Monitoring and renewal

Compliance does not stop once a supplier is onboarded. EUDR requires ongoing due diligence throughout the relationship.

• Reassess risk regularly: Review supplier risk profiles periodically, especially if sourcing regions change, new farms are added, or country benchmarks shift. Keep a schedule for annual (or more frequent) reviews, especially for high-risk origins.
  
• Renew and update documentation: Ensure suppliers renew expiring documents and keep GPS or traceability records up to date. Make EUDR performance part of your renewal and performance reviews.
  
• Keep an audit-ready trail: Maintain all data, DDS records, and supplier documentation in a secure, organized system for at least five years. Be ready to retrieve everything quickly in case of an audit or inspection.
  
• Monitor for issues: Watch for deforestation alerts near supplier farms, expired certifications, or concerns raised by third parties. Set up a process for escalation and remediation if something flags your attention.

What procurement teams need from suppliers

To make EUDR work in practice, procurement teams need structured, verifiable data from suppliers. This is not about vague ESG commitments; it is about operational details that allow companies to complete risk assessments, generate DDS filings, and pass audits.

Here is what you will need to request and manage:

• Geolocation of origin (GPS coordinates): For every farm or plantation in the supply chain, suppliers must provide precise GPS coordinates in GeoJSON format. If sourcing from smallholders, this may involve multiple plots.
  
• Production or harvest date: EUDR compliance depends on when the commodity was produced. You will need to collect the harvest or production date for each batch. This helps confirm alignment with the deforestation cut-off and supports the DDS timeline.
  
• Proof of legality: Suppliers must show the product was legally produced under all relevant local laws, including land use, harvesting, labor, and environmental requirements. This can include permits, certificates, or signed legal attestations. Ideally, this is backed by official documentation. If suppliers rely on sustainability schemes, ensure those schemes actually cover legal compliance, not all do.
  
• Documents to support the risk assessment: In addition to basic traceability data, suppliers must provide documents that help determine whether there is a non-negligible risk of deforestation or illegality. This includes maps, declarations, evidence of control systems, certifications, and audit reports.
  
• Due Diligence Statement references: If your supplier is the operator, they are required to submit the DDS. In that case, you will need to collect and validate the DDS reference number to include in your own simplified declaration. This should be provided alongside delivery documents and logged in your procurement or compliance system.

Collaboration is critical

Collecting EUDR data and assessing or mitigating risks cannot be done in isolation. Procurement teams need active collaboration with suppliers to gather information, clarify gaps, and respond to changes in sourcing or risk status. That means setting expectations clearly, explaining the reasons behind requests, and keeping communication open.

Approaching EUDR together, rather than as a one-sided compliance burden, makes it easier to solve problems early, identify incomplete data, and find practical solutions. When suppliers understand what is required and feel supported, not penalized, they are far more likely to provide the needed data consistently.

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How software can help with procurement integration

EUDR due diligence involves hundreds of small steps: data gathering, supplier follow-ups, shipment checks, document storage, and timely declarations. Trying to manage all of this manually can lead to delays, errors, or non-compliance, especially at scale. That is where software becomes essential. The right system turns due diligence into a structured, automated part of your procurement process.

Here is what to look for:

• ERP integration: Sync with your ERP or procurement platform so that every purchase order is linked to origins, supplier data, shipment information, and due diligence status.
  
• Centralized data collection and storage: Keep all geolocation files, legality documents, DDS references, and supplier inputs in one structured, secure place, searchable and audit-ready without extra effort.
  
• Automated logic based on operator role: The system should automatically determine your obligations. If you are importing raw materials, it should guide you to generate a DDS. If you are downstream in the EU, it should prompt you to reuse the supplier’s DDS reference and submit a simplified declaration.
  
• Built-in risk assessments: The tool should evaluate and flag standard or high-risk shipments and tailor the depth of due diligence accordingly.
  
• Mitigation workflows: If risk is not negligible, the system should trigger predefined mitigation actions, such as requesting extra documents, escalating to audit, or pausing shipment approval until cleared.
  
• Task automation: The tool should guide your team step by step by automatically assigning due diligence actions, generating reminders, and flagging missing data based on the context of each order.
  
• Audit-ready traceability: Every order should be automatically linked to its farm or plot of origin, with all supporting documents and risk evaluations stored in one place. If an authority requests proof, you should be able to trace any product back to source in seconds.
  
• Connection to TRACES: A direct integration with the EU’s TRACES platform allows you to generate, submit, and retrieve DDS filings without manual uploads or duplicated data entry.

How Coolset helps you stay on track

Coolset’s platform is designed to simplify EUDR compliance for companies of all sizes. It enables businesses to:

• Automate DDS generation: Pull supplier data into pre-configured DDS templates. Save time and reduce errors.
• Validate origin data: Flag missing GPS coordinates, incomplete documents, or mismatches.
• Benchmark risk: Incorporate EU country risk scores to scale due diligence efforts based on sourcing location.
• Audit-proof recordkeeping: Maintain all DDS, supplier documents, and risk assessments in a secure archive.
• Integrate with ERP tools: Pull product data and sourcing details directly from procurement or supply systems.

Coolset’s tools are pre-configured to support EUDR documentation requirements and designed for ESG or compliance teams that need to move fast.

The solution is launching later this year and you can get early access by joining the waitlist.

FAQ – Procurement and EUDR

1. What are the EUDR requirements for procurement teams?

Procurement teams are directly responsible for enabling EUDR compliance. This means ensuring that no regulated product is purchased without collecting all required due diligence information. To make this operational, procurement must embed checks before any purchasing decision is made. This includes screening suppliers during onboarding, updating contracts with EUDR clauses, and confirming that compliance data is complete before placing an order.

Just as importantly, success depends on strong supplier relationships and clear communication. Suppliers need to understand exactly what they are responsible for and why it matters. When procurement teams engage suppliers early and build in expectations from the start, it becomes much easier to collect reliable data and reduce back-and-forth during shipment cycles.

2. What supplier data is required for EUDR compliance?

To comply with Article 9 of the EUDR, companies must collect a specific set of data for every shipment of in-scope commodities. This includes:

• Geolocation of the production plot (as coordinates or polygons)
• Commodity and product type
• Quantity (volume, weight, or number of units)
• Country of production
• Production or harvest date
• Proof of legality
• Confirmation of deforestation-free status
• Due Diligence Statement (DDS) reference (if the supplier is the operator)

In addition to these legal minimums, procurement teams must gather the information needed to conduct a proper risk assessment. This includes how the supplier manages its supply chain (e.g., direct vs. indirect sourcing), whether they rely on certifications or internal controls, whether they operate in a high-risk region, and how they treat and segregate materials in mixed batches. It is not just about the data points, it is about understanding how the supplier ensures that deforestation-free, legal sourcing is maintained across operations. This context is key to determining whether risk is negligible or requires mitigation.

3. How do I onboard suppliers for EUDR due diligence?

The first step is building a collaborative environment. Many suppliers, especially smaller ones, may be unfamiliar with EUDR or uncertain about what is being asked of them. It is essential to clearly explain the regulation, what due diligence means in practice, and how they can support compliance without fear or confusion. When suppliers understand the reasons and feel supported, they are more likely to engage constructively and provide the right information.

Start with geolocation. It is the anchor for everything else. Without it, you cannot assess deforestation, assign risk, or complete a DDS. But it is also one of the hardest pieces of data to obtain, particularly in fragmented or smallholder-based supply chains. That is why your onboarding process should be designed to gather this information first.

Update your supplier intake forms to include all EUDR-required fields. Include EUDR obligations directly in your contract templates so expectations are clear and legally binding. If possible, provide a short, plain-language guide or checklist so suppliers know exactly what they need to submit and why. The goal is to reduce friction, avoid surprises, and ensure that by the time you are ready to place an order, all due diligence data is already in place.

4. What happens if a supplier cannot provide GPS or legality data?

If a supplier cannot provide geolocation or legality proof, the product cannot legally be placed on the EU market. This is non-negotiable. You may be able to support them in closing gaps, for example, through remote sensing tools, sourcing from mapped cooperatives, or collecting new documentation. But if, after this, the risk remains non-negligible, you may have to stop sourcing from them.

This is exactly why procurement processes must begin with early screening and structured onboarding. A supplier who is not able, or willing, to meet core EUDR requirements is a liability, not just from a compliance standpoint, but from a supply continuity perspective as well.