The era of box-ticking compliance is over. EU Deforestation Regulation (EUDR) compliance requires you to provide clear evidence that you have produced your products in a legal and responsible manner.
Those who continue to rely on country risk profiles and voluntary questionnaires alone are setting themselves up for failure.
A complex legal landscape
EUDR compliance is not just about the origin of commodities; it is also about how they are produced.
Producers must produce commodities in accordance with the laws of their country. As stated in Article 3(b) of the EUDR. This includes a complex set of laws. These laws cover land use rights, environmental protections, labour rights, and human rights (Article 2(40)).
This is where things get complicated. Land-use legislation and applicable laws vary significantly between countries and often even between regions within countries. Knowing that a farm is outside a national park is not enough.
You must ensure that the farm complies with local laws. This includes zoning laws, conservation rules, and agreements on Indigenous rights. You must also consider other relevant regulations.
Country risk profiles lack granularity
Country risk profiles provide a general overview of governance and enforcement issues. However, they lack the granularity needed to pinpoint risk on the ground. Two neighbouring farm plots in the same country could have radically different legal standings. One may be fully compliant with national legislation, while the other may be operating illegally within a protected area.
Without detailed, plot-level information, you're flying blind and are exposing yourself to regulatory risks.
Questionnaires: illusion of security without additional information
Many suppliers genuinely believe they are operating legally, but misunderstandings and outdated knowledge of local regulations are common. Voluntary questionnaires only capture what the supplier knows or chooses to disclose. Very few surveys are designed to verify compliance against the whole body of local laws independently.
This is why it’s essential to run plot-level analytics against databases that contain the nuances of local laws and legislations within the risk assessment.
However, questionnaires play a key role in complementing quantitative solutions. They can provide valuable context where high-quality reference data is lacking, especially in regions with limited data infrastructure or for complex topics such as human rights, tax evasion, fraud, and specific aspects of land rights. There simply isn’t a reliable dataset that can confirm, for instance, whether specific farms within a supplier’s network are at risk of complicity in forced labour. Instead, we need a process-oriented approach, and questionnaires provide one structured way to surface these risks.
When combined with tools like Meridia Verify® for geospatial plot-level analysis, questionnaires can help fill in the blind spots, enriching our understanding of risk where quantitative methods alone don’t provide a complete picture.
Assessing compliance risks in protected areas
Our datasets for scalable, quantitative risk assessment focus on protected areas and local land use laws. Protected areas, such as nature reserves and national parks, are often subject to strict limitations on agricultural activities. However, in many countries, farming within these areas can be permitted under specific conditions, and sustainable use of officially protected areas is essential to the regional economy and your supply chain. Therefore, assessing compliance risks in protected areas with consideration for local laws is vital.
That’s why Verify provides nuanced risk scoring and targeted resolution recommendations to guide the type of documentation or assurance required from suppliers, rather than a general box-checking exercise that may not be sufficient for a regulatory audit.
Taking control through actionable due diligence
The path forward demands rigour, transparency, and evidence:
- Map and monitor farm plots to identify overlaps with protected areas and restricted zones.
- Rely on Meridia to cross-reference your operations with national and local legislation, not just general country risks.
- Collect verifiable documentation showing compliance with specific legal requirements, particularly when farming activities occur near sensitive areas.
- Use independent data sources and field verification to validate supplier claims, ensuring your compliance is solid and reliable.
Data-driven due diligence to meet EUDR requirements.
Organisations that use strong, data-driven due diligence will meet EUDR requirements. They will also protect their supply chains for the future.
The ICE CoT platform supports thorough due diligence for trading compliant cocoa and coffee. It includes country-specific legal production questionnaires and a rigorous plot-level geospatial analysis, developed by Meridia, against a database of local laws to assess legal production risks.
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