Policy Briefing — July 2, 2025

Executive briefing: The six-month grace period that micro and small enterprises received under Article 34 of Regulation (EU) 2023/1115 ends on June 30, 2025. As of July, all operators placing cattle, cocoa, coffee, oil palm, rubber, soy, and timber commodities or derived products on the EU market must deliver complete deforestation-free due diligence statements into the Information System and retain geolocation evidence back to the plot of production. Customs authorities will block consignments lacking the mandatory statement identifier, making July shipments the first to face full enforcement for smaller traders.

Immediate compliance actions

Due diligence statements. Build templates that capture Harmonised System codes, country of production, and negligible-risk justification so declarations can be generated for every customs declaration starting July 2025.
Geolocation validation. Collect polygon coordinates for all smallholder plots supplying July consignments, documenting satellite imagery checks, forest-risk benchmarking, and risk mitigation decisions.
Risk classification. Update supplier risk scores against the Commission’s country benchmarking system, noting that even low-risk ratings still require traceability and documentation.

Data and supplier controls

System integration. Connect procurement and customs filing platforms to the EU Information System APIs so statement identifiers flow automatically to declarants and customs brokers.
Record retention. Archive due diligence files, satellite imagery, and third-party verification reports for at least five years to satisfy competent authority inspection powers.
Corrective action plans. Establish remediation workflows to suspend non-compliant suppliers, track farm-level mitigation progress, and document notifications to national authorities.

Stakeholder coordination

Finance teams. Quantify penalty exposure—member states can issue fines up to 4% of annual EU turnover and confiscate goods for missing statements.
Customs brokers. Share standard operating procedures for flagging high-risk consignments, escalating missing statement IDs, and responding to documentary requests within the set deadlines.
Board oversight. Brief audit committees on July enforcement to ensure sustainable sourcing metrics align with CSRD, CSDDD, and voluntary ESG reporting narratives.

Sources

Zeph Tech coordinates EUDR compliance sprints—mapping geolocation data, integrating customs identifiers, and arming sustainability leaders for competent authority audits starting July 2025.