A jar of chocolate cream illustrates how complex EUDR due diligence really is in practice.

Let's take the well-known spread that most of us have known since childhood: Nutella. A spread that almost everyone knows, with a manageable ingredient list and a global supply chain that, at first glance, seems easy to organize. Nevertheless, this one product alone contains three raw materials that originate from EUDR-relevant sources: cocoa, palm oil, and soy. Anyone placing products containing these ingredients on the market must, from December 30, 2026, know precisely which obligations apply, where, and to whom.

This product and its components represent a challenge facing purchasing teams in many industries, including food, cosmetics, packaging, chemicals, and automotive. Anyone with even a single EUDR-relevant raw material in their supply chain must be able to provide complete and verifiable proof that it was produced without deforestation by the end of 2026. Or, to paraphrase a Nutella slogan: Only products labeled "deforestation-free" must truly be deforestation-free.

This article uses Nutella as an example to illustrate the specific requirements of the EU Deforestation Regulation, highlighting the real challenges in raw material procurement and how purchasing teams can now proceed in a structured manner. Specifically, it covers:

• What the EUDR regulates and who it affects

• Why a chocolate cream is an ideal example of multi-stage supply chain requirements

• What specific due diligence obligations do purchasing teams face?

• What a structured procurement process for EUDR compliance looks like

• What the EU Commission's simplification package of May 4, 2026 changes in this regard

A jar of Nutella, three EUDR-relevant raw materials, and the question: How many compliance obligations really need to be fulfilled?

The ingredient list of the popular hazelnut chocolate spread is: sugar, palm oil, hazelnuts, skimmed milk powder, low-fat cocoa, emulsifier lecithins (soy), vanillin, thus including three raw materials relevant to the EUDR (European Union Debt Enforcement Directive). All three are cultivated in tropical regions that are among the most deforested areas in the world. Anyone who manufactures and markets this product in the EU will face a concrete problem from December 30, 2026, onwards if they cannot prove that these raw materials were cultivated on land that was not deforested after December 31, 2020.

This sounds logical and straightforward at first glance, but in practice it's more difficult than it initially appears . For example, cocoa and palm oil are very quickly blended on the global market, making them difficult to trace. A cocoa bean mix from Côte d'Ivoire (the world's largest producer), compiled by several cooperatives, contains beans from potentially hundreds of different farm plots, each of which must be georeferenced and verified to be free of deforestation. Even well-organized purchasing teams quickly reach their structural limits here.

Therefore, the question is absolutely justified: what happens if this proof is missing?

The regulation stipulates fines of at least four percent of EU-wide annual turnover, in addition to the confiscation of the goods in question and the resulting consequences, such as production stoppages and supply disruptions. For purchasing teams, this means that anyone who fails to establish robust documentation about their suppliers now will face a structural problem shortly before the deadline, one that cannot be resolved quickly.

What the EUDR regulates and why it goes far beyond food

The EU Regulation on deforestation-free products (EU) 2023/1115, or EUDR for short, was adopted by the European Parliament and the Council of the European Union in May 2023. The EU deforestation regulation will become binding for large and medium-sized enterprises from 30 December 2026.

Their principle is simply stated: Raw materials and products made from them that are placed on the EU market or exported from the EU must not contribute to deforestation. Anyone who cannot prove this is not allowed to market them.

The regulation covers seven raw materials: cocoa, coffee, palm oil, soy, rubber, timber, and cattle, as well as a wide range of products made from them, including chocolate, cocoa butter, palm oil, soybean oil, rubber products, and wooden furniture. Annex I of the regulation lists these products using HS codes. Those who examine it often find that their own exposure to the EUDR extends further than initially assumed.

Following a second postponement by amending Regulation (EU) 2025/2650, the due diligence obligations will apply from 30 December 2026 for large and medium-sized enterprises and micro and small enterprises in the timber sector. Other micro and small enterprises will be granted a transitional period until 30 June 2027. The European Commission explicitly ruled out a third postponement in its report of 4 May 2026.

Three raw materials in one product, but not the same obligation three times.

Many purchasing teams assume that for a finished product like chocolate spread, each EUDR-relevant raw material triggers its own due diligence obligation. However, the regulation differentiates significantly here, depending on the form in which a raw material is placed on the market.

The European Commission has established clear regulations for compound products containing multiple EUDR-relevant raw materials in FAQ 1.3 of its official guidelines, published by the Federal Office for Agriculture and Food (BLE). The HS code 1806 applies to the final product, chocolate cream, and the relevant raw material is cocoa. Therefore, due diligence for the final product extends exclusively to the cocoa-based components: cocoa mass, cocoa butter, and cocoa powder. Palm oil and soy lecithin do not, in themselves, trigger any independent due diligence obligations for the finished chocolate cream product.

However, this regulation applies exclusively to the final product. As soon as the same raw materials are procured separately and placed on the market as independent products because they are only processed into a cream within the EU, a completely different logic applies.

If palm oil and soy nevertheless become subject to EUDR compliance requirements

Anyone who imports palm oil or soy lecithin directly from third countries—because, in our example, the chocolate cream is produced within the EU—is placing these products on the EU market for the first time as independent relevant products within the meaning of Article 3 of Regulation (EU) 2023/1115 and is therefore the initial distributor of each of these raw materials , subject to full due diligence obligations, regardless of the final product. This obligation includes gathering information in accordance with Article 9 of the Regulation, conducting a risk assessment, and submitting a due diligence declaration to the EU information system.

Anyone sourcing these raw materials from a European supplier who has already imported them in compliance with EUDR is considered a downstream market participant and must, according to the regulation, ensure that the due diligence obligation has actually been fulfilled by the initial distributor and document the reference number of the existing due diligence declaration. If this proof is lacking, the downstream market participant remains legally liable.

In summary, the Nutella case: Anyone placing the finished chocolate spread on the EU market only needs to demonstrate cocoa compliance for the final product. Those who import palm oil and soy lecithin separately require a separate, complete due diligence declaration for each of these raw materials. However, those who source these raw materials from a European supplier must demonstrably have the supplier's reference numbers. In all three cases, the purchasing department is responsible for ensuring that the applicable compliance requirements are fully met.

What the simplification package of May 4, 2026 specifically changes

Many companies had hoped that the Commission would reopen the regulation or postpone the deadline further. The simplification report of May 4, 2026, makes it clear: This will not happen. The application date of December 30, 2026, is set.

Three aspects of the package are particularly relevant for purchasing teams:

• Firstly, certain palm oil derivatives and instant coffee are to be newly included in the scope of application, which may lead to expanded coverage for products containing processed palm oil fractions.

• Secondly, the EU information system was made available again in June 2026 with updated features, including simplified forms and a grouping function.

• Thirdly, according to the Commission, the estimated annual compliance costs have decreased by around 75 percent compared to the original version, from approximately 8.1 billion euros to around 2.0 billion euros, due to the simplifications introduced.

This is how a purchasing team designs the EUDR-compliant procurement process.

To ensure EUDR compliance in raw material procurement, the following approach is recommended:

Step 1: Raw material mapping and impact analysis

The first step is therefore to systematically examine all raw materials and ingredients in your portfolio to determine whether they fall under Annex I of the EUDR and at which stage of the supply chain your due diligence obligations apply. Distinguishing between the impact on the final product and the impact on individually purchased raw materials is crucial, as it determines who specifically needs to submit which declaration. An analysis using the HS codes provides the necessary clarity and forms the basis for all further steps.

Step 2: Supplier assessment according to maturity level for the EUDR regulation

Once it has been determined whether the supplier is affected, the crucial question arises as to whether the suppliers are actually able to provide the necessary evidence. This includes systematically checking whether suppliers are registered in the EU information system, whether they can provide reference numbers for their due diligence declarations, and whether geodata is available for the respective cultivation areas.

Step 3: Contractual anchoring of EUDR obligations

Due diligence obligations cannot be resolved through goodwill alone, but must be contractually enshrined. This means supplementing supply contracts with explicit EUDR compliance clauses, including documentation requirements, disclosure obligations regarding changes in origin, and clear consequences for non-compliance.

Step 4: Data strategy and system integration

The EUDR essentially represents a data requirement that can hardly be managed with manual processes. Anyone who has to manage geolocation data, harvest periods, countries of origin, and DDS reference numbers for each shipment will quickly reach the limits of manual processes. Therefore, integrating this data into existing ERP and master data systems, as well as connecting to the EU information system, are not optional measures, but rather operational prerequisites for EUDR compliance to function effectively in day-to-day purchasing operations.

Step 5: Continuous monitoring and supplier communication

EUDR compliance requires an ongoing process that must be managed simultaneously at multiple levels. Suppliers can change their growing regions, cooperatives, or sub-suppliers, often without proactively informing the purchasing department, which means a supplier's compliance status can change at any time. Furthermore, each individual shipment requires a valid due diligence declaration that refers specifically to that batch, delivery period, and origin, as a previous declaration does not generally cover a new shipment.

Purchasing teams therefore need a structured review process that actively checks supplier information, proof of origin and due diligence declarations with every new delivery, not just once during the initial assessment.

Key Takeaways

Only products labelled as deforestation-free must actually be deforestation-free. From December 30, 2026, this applies to every EUDR-relevant raw material in your supply chain, regardless of whether you import it yourself or not.

Nutella exemplifies a challenge that extends far beyond the food industry, as even a seemingly simple product can trigger various compliance scenarios with its three key raw materials. For example, someone who knows their cocoa supplier but doesn't know which cooperative in which district the last batch came from faces an EUDR problem that cannot be resolved in the final weeks before the deadline.

To help you and your purchasing organization be better prepared, here is a summary of the most important findings from this article.

• The EUDR will become mandatory for all large and medium-sized enterprises from 30 December 2026, with any further postponement explicitly ruled out according to the Commission report of 4 May 2026.

• For compound products like chocolate spread, the HS code of the final product determines which raw material triggers due diligence. For HS code 1806, this is exclusively cocoa, while palm oil and soy lecithin only create a separate due diligence obligation if they are placed on the market separately as independent products. To avoid unpleasant surprises, we recommend that you complete the analysis and inventory as soon as possible.

• According to the regulation, anyone who sources EUDR-relevant raw materials from a European supplier is obliged to ensure that due diligence has actually been carried out upstream, otherwise they remain legally responsible.

• Procurement is the crucial lever for EUDR compliance, as it must establish transparency regarding origin, geodata and due diligence declarations before a batch reaches the EU market.

Ensuring long-term EUDR compliance requires more than a one-off analysis. Our whitepaper demonstrates an automated approach to raw material procurement and outlines the specific steps purchasing teams must take.