Why is an EUDR stack essential for compliance?

An EUDR stack is essential to automate the complex due diligence and data management needed to prove that products are deforestation-free and legally sourced, as required for compliance. Compliance means submitting a Due Diligence Statement (DDS) before every shipment is dispatched. Following the formal adoption of the delay through Regulation (EU) 2025/2650 on 19 December 2025, large and medium operators and non-SME traders must comply by 30 December 2026. Micro and small operators established as such by 31 December 2024 have until 30 June 2027. Customs will block goods without a DDS, and penalties can reach at least 4% of the total Union-wide turnover.

EUDR combines two domains. First, governance and reporting (Article 12) requires companies to set up internal due-diligence systems, define risk thresholds, and publish annual reports on compliance. Second, operational controls (Articles 9–11) demand that supply chains collect data (GPS coordinates, land permits, etc.), assess risks, and apply mitigation before shipments depart. In practice, that means ESG teams must design the compliance framework while procurement and supply chain teams collect the data and execute controls. 

Because it spans both strategy and logistics, no single department can “own” EUDR. ESG teams lack the supplier networks to gather raw data, while operations lack the governance mandate to structure and report it. Without an integrated workflow, a true EUDR stack,  companies end up in silos risking blocked shipments at EU customs checkpoints, financial penalties, supplier disengagement from repetitive requests and reputation damage.

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What are the core layers of an EUDR + ESG Workflow?

A complete EUDR stack has three layers:

1. Governance layer (ESG): This is where the due diligence system is built. The role of the ESG team is to:

• Translate the regulation into company policies.
• Map EUDR’s legal requirements onto processes, including defining what “negligible risk” means for their business.
• Determine exactly what supplier data is needed, for example, plot-level coordinates and proof of legality.
• Handle any required reporting, such as the annual due-diligence reports operators must file for non-SMEs.
  

2. Operational layer (Supply Chain/Procurement): This covers the hands-on work with suppliers. The role of the supply chain/procurement team is to:

• Gather the required data on each shipment, for example, GPS plots of where the commodity was grown and copies of land-use permits.
• Run the risk analysis for every order and, if the rules require, trigger mitigation actions on a shipment-by-shipment basis. 
• Embeds EUDR checks into supplier contracts and screening, so that suppliers know what information to provide up front.
• Ensure that there is a DDS in the EU TRACES system before the shipment is executed. Or, for companies sourcing from micro or small primary operators, obtain and record the reference number of an existing DDS in lieu of a new submission.
  
  

3. Integration layer (Platform/Tech): Tech and EUDR implementation goes hand in hand as a successful platform integration needs to work closely with your ERP systems. The role of the technical team is to:

• Produces a good compliance tool that provides shared workflows where supplier inputs (e.g. data uploads and documents) automatically feed into ESG’s risk assessments and reporting templates. 
• Organises a due diligence system that is a well-integrated, fixed part of the business that operates better than systems that operate independently. 

Each layer feeds the next. ESG builds the framework, supply chain populates it with real data, and the platform ensures the flow from one to the other is smooth and auditable. 

Who is responsible for each part of compliance?

EUDR compliance is shared across teams, with ESG responsible for governance and reporting, procurement handling supplier engagement and operational execution, legal providing interpretation and defense, and IT ensuring data integration and traceability systems. 

• ESG teams: Design and maintain the due diligence system. This includes mapping EUDR’s legal requirements to company processes, defining what counts as “negligible risk”, coordinating required public reporting (such as the annual DDS report for non-SME operators), and training internal teams and suppliers on how to apply these rules in practice.
• Supply chain (procurement) team: Engage suppliers to collect the required data (geolocations, legal documents, etc.) and execute risk mitigation actions on shipments. In practice, procurement is the operational engine of EUDR compliance, ensuring each purchase order is linked to traceability data and that every shipment has its DDS reference before leaving the warehouse.
• Legal team: Are consulted for interpretation and defense. They Review the company’s risk criteria and compliance policies to make sure they align with the regulation. When complex or ambiguous situations arise, legal authorities can define responsibilities in edge cases and guide the ESG team in interpreting the law appropriately. If regulators come knocking, legal ensures the due diligence methodology is defensible and audit-ready, validating that the EUDR framework holds up in practice.
• IT or data teams: Manage technical integrations, maintaining up-to-date reports and dashboards, and ensuring smooth data flows across procurement and compliance platforms. For example, utilizing software to ensure every purchase order is linked to origins, supplier data and due diligence status. 

Adopting a RACI model (Responsible, Accountable, Consulted, Informed) helps prevent overlaps and maps ownership of EUDR compliance. By clearly assigning roles within the RACI framework, companies avoid the common pitfall of finger-pointing, clarify accountability and create a smoother path to compliance.

How do I avoid duplicated work across CSRD and EcoVadis?

You can avoid duplicated work across CSRD and EcoVadis by centralising EUDR compliance data in a unified system, standardising formats, and reusing supplier due diligence and traceability evidence to satisfy both reporting frameworks consistently. 

The EUDR aligns with the Corporate Sustainability Reporting Directive (CSRD), which necessitates companies to disclose information on sustainability matters. Specifically, the European Sustainability Reporting Standards (ESRS) (ESRS E4-2, require companies, if found relevant by the company’s double materiality assessment,  to report on policies to address deforestation. By integrating EUDR compliance data, companies can substantiate their deforestation policies and demonstrate adherence to both EUDR and CSRD requirements. In practice, this means referencing EUDR due diligence policies and traceability systems directly within CSRD reports, ensuring disclosures are consistent across frameworks and supported by verifiable data.

EUDR compliance data can also provide evidence for the EcoVadis questionnaire. The EcoVadis assessment platform assesses corporate sustainability performance, evaluating companies on various themes, including sustainable procurement. Companies can operationalize this by linking supplier due diligence checks carried out under the EUDR directly to EcoVadis assessments, using supplier traceability data and risk screening results as documented proof of sustainable procurement practices.

Key strategies:

• Centralising data access through a unified compliance system, such as Coolset’s platform, ensures that once supplier data is entered, it can be seamlessly integrated into various disclosure documents, including those for EUDR, CSRD or EcoVadis. This approach minimizes supplier fatigue and also ensures consistency across different reporting requirements.
• Standardizing data formats is equally crucial. By enforcing common units and formats during data entry, companies can prevent the need for manual data cleaning and conversion when reusing information across different reports. Require common units and formats everywhere. A well-configured system can automate these processes, saving time and reducing the risk of errors.
  
  

By focusing on common data and processes, teams cut redundant work and avoid driving suppliers crazy. EU guidance says that the verifiable data collected for EUDR due diligence can be integrated into the required CSRD sustainability reporting, ensuring a consistent and auditable section within the annual report. This integrated approach transforms compliance from a fragmented task into a streamlined process, ensuring data consistency, verifiability, and a more reliable narrative for all stakeholders.

What technical tools are needed to support compliance workflows?

Achieving an end-to-end EUDR compliance workflow at scale means leveraging the following software and integrations:

• ERP and system connectors: The platform should sync with your core enterprise systems (SAP, NetSuite, Dynamics, etc.). This ensures that when a purchase order is created, details like supplier, product, quantity and shipment data automatically flow into the due diligence tool.
• Supplier engagement workflows: The software should send structured requests (for geolocation, harvest certificates, etc.) and track who has responded. Automated outreach to suppliers through reminders, error flags, and supplier self-service portals can speed up data collection. The goal is to eliminate spreadsheet chaos. A digital workflow handles the hundreds of small tasks needed (data uploads, version control, follow-ups).
• Traceability management tool: Creates a continuous "chain of custody" that links every product you sell back to the specific plot of land where its raw materials originated. This process is crucial for EUDR compliance because it addresses the challenge when materials from various sources are physically mixed, making it difficult to trace an individual unit. By creating a verifiable digital record for each material, these tools maintain a clear line of sight from the finished product to its source, which is critical for due diligence and audits.
• Risk logic engine: A key feature is built in deforestation and legality risk assessment. The platform should embed scoring models or allow ESG teams to configure them (e.g. country-level risk benchmarks, satellite imagery checks). As data comes in, the system can automatically flag “non-negligible” risks or prompt mitigation using satellite data, country related public data and supplier inputs.
• DDS automation and TRACES integration: The ultimate output is the official DDS for each shipment. The tool should auto-generate the DDS in the format accepted by the EU’s TRACES system. This removes manual paperwork: once all required data is confirmed in the system, a click can produce the DDS, complete with reference number.
• Audit trail and reporting: The software must keep a full record of every step – who submitted which document and when, changes to risk decisions, and versions of each DDS. This auditability is critical for inspections. It should also support exporting the data for reports (for regulators or internal governance). A shared database ensures that evidence is linkable – for example, each DDS record ties back to the original supplier documents and approvals.

Coolset’s platform combines these features, creating a single system that supports multi-framework compliance ensuring one dataset serves EUDR, CSRD, EcoVadis, and CBAM reporting. 

What is the benefit of organising an EUDR stack now?

Building the EUDR stack now creates a foundation for proactive supply chain management, faster reporting cycles, and stronger operational resilience. Acting early delivers concrete benefits:

• Meet compliance deadlines: The regulation takes effect on December 30, 2026 for large and medium operators (non-SME) and June 30, 2027 for micro and small operators. Early adopters will be ready well before enforcement ramps up.
• Avoid blocked shipments: Customs authorities will not clear goods without a valid DDS. Companies chasing last-minute paperwork risk having shipments held at the border. An integrated stack ensures every shipment gets its DDS on time.
• Reduce supplier fatigue: A unified workflow means suppliers get one set of questions, not multiple requests from different departments or for different regulations. This builds goodwill and improves data quality.
• Strengthen ESG credibility: Traceable supply chains are a market differentiator. Today’s investors demand transparency: a recent survey found nearly three-quarters of investors rate supply chain governance as “very” or “extremely” important. Demonstrating EUDR compliance (with fully documented due diligence process) signals strong ESG management and can enhance reputation and ratings.

Setting up a shared EUDR-ESG system now means adding new regulations later will require much less effort. The data backbone you build will serve upcoming rules as well. 

Companies that invest in the integrated EUDR stack today minimize disruption and build resilience. They’ll transition to the new rules smoothly, avoid penalties and delays, and be better positioned to respond to future sustainability mandates.

Reach out to our team to see our EUDR module in action.

FAQ – Building an EUDR stack

What is the EUDR stack? 

A joint workflow where ESG governance and supply chain execution are unified into a single compliance backbone. It means one system handles both the policy side (risk definitions, reporting) and the operational side (supplier data, DDS submissions).

Does EUDR data overlap with CSRD or EcoVadis? 

Yes, but the overlap is indirect. EUDR data can support CSRD disclosures by evidencing policies on deforestation (ESRS E4-2, para. 24(d)) or strengthen EcoVadis scores by serving as proof under the “Sustainable procurement” theme.

Who is accountable if ESG and supply chain disagree? 

Legally, the operator (or non-SME trader) placing products on the EU market remains responsible. In practice, the ESG team defines the rules and the supply chain team executes them. Both teams must align, but the final liability rests with the operator.

How can SMEs build a simplified stack? 

Not all SMEs are treated equally. Micro and small operators can submit a simplified declaration referencing an existing DDS, with a deadline of 30 June 2027. Medium operators face full DDS obligations from 30 December 2026. For micro and small operators, a lighter stack centred on recording upstream DDS reference numbers is sufficient.

Can certifications replace the EUDR stack? 

No. EUDR guidance declares that operators must exercise due diligence prior to placing relevant products on the market or exporting them. However, certifications can support EUDR due diligence by being used as a risk mitigation measure, but only if the specific risk is clearly understood.