Why a one-off impact analysis quickly becomes outdated and how your purchasing team can keep track .

This time it's Lisa's turn to bring in new instant coffee for the office, a product that has been inconspicuous in every office and home kitchen until now. However, as part of the EUDR simplification package of May 4, 2026, instant coffee was added to the list of products covered by the EUDR in Annex I. The same proposal calls for the removal of hides, skins and leather of cattle, as well as retreaded tires.

This is precisely the problem many purchasing teams face, regardless of whether they are working with the HS codes for a single product, like our chocolate cream from the last post. They need to consider their entire portfolio. As the Nutella example illustrates, even classifying a single product with multiple raw materials is challenging. In practice, however, a purchasing team rarely deals with just one product, but rather with hundreds or thousands of purchased items, spread across multiple product groups, suppliers, and countries. New products are ordered and old ones replaced almost daily. Therefore, a list of a company's purchased products, once compiled, is never truly complete; it must become a living, evolving process, constantly updated with new products.

This article is not about a single product, but about how a purchasing team can keep track of its entire product landscape in compliance with EUDR regulations. Specifically, we answer:

• Which purchased products fall under the seven EUDR commodity groups and their derivative products, and how a complete, up-to-date list across all commodity groups is created.

• How far back in the supply chain visibility actually extends – to the cultivation area with geolocation or only to the first intermediary?

• Which products and suppliers need a due diligence declaration and how this can be achieved with a prioritized approach.

• How it will be ensured that products without a valid due diligence declaration no longer enter the EU market from the cut-off date.

  
  

The purchasing team has a product list with several thousand items, but how many of them are truly relevant under EUDR? Most purchasing organizations in medium-sized and large companies maintain several thousand active items or ingredients in their master data.

Those who only check the individual raw materials but overlook the downstream products quickly develop blind spots in their own portfolio. To make matters worse, this list is not static , as it must be continuously expanded and reviewed. Even a complete and up-to-date product list leaves a second, often underestimated question unanswered: How reliable is the knowledge about the origin of these products, really?

Many purchasing teams know their direct suppliers well, but lose track as soon as a raw material passes through an intermediary, a cooperative, or a processor serving multiple producers, as the example of the cocoa bean mix from several hundred farm plots in the last post illustrated . It is precisely at this point that a formality becomes a genuine structural risk, because without visibility back to the cultivation area, no reliable due diligence declaration can be issued. Even if a company knows where the gaps in the value chain lie, the question of prioritization remains. With limited internal, personnel, or time resources, it is impossible to simultaneously bring every product and every supplier up to the same qualitative standard for EUDR-relevant information . Those who proceed without prioritization risk investing significant effort in low-risk products while the truly critical supply chains remain unaddressed until the deadline approaches.

Why a complete product list requires more than a one-time comparison with Annex I.

The seven product groups of the EUDR – cattle, timber, cocoa, soya, palm oil, coffee, and rubber – sound manageable. However, Annex I of the regulation lists, each with its own HS code, a considerable number of products derived from these, ranging from chocolate and cocoa butter to soya oil and palm oil derivatives, and on to furniture, tires, and beef products. Complete product mapping therefore means checking every purchased item against this HS code list. For purchasing teams, this means that product mapping cannot be a one-off project, but rather a recurring check for each order, ideally supported by their own ERP and master data systems. This ensures that changes to the scope of application are reflected in the portfolio promptly and don't only come to light when a shipment gets stuck at the border.

The EUDR requires, according to Article 9, geolocation of the cultivation or production area for each relevant product. For areas up to four hectares, a single point suffices; larger areas require a polygon; and for cattle, one point per holding is required for the entire lifespan. However, according to the so-called "once-only" principle, this requirement primarily applies to the initial distributor, i.e., the company that first places the raw material on the EU market. Downstream market participants do not need to collect their own geodata but must document and retain the reference number of the existing due diligence declaration.

This is precisely what leads to a visibility problem in practice, because there are often several stages between the cultivated area and the company's own goods receipt: producers, cooperatives, intermediaries, processors, usually spread across multiple countries. As long as each of these stages passes on its reference numbers without gaps, the system works. However, as soon as one stage bundles the origin of several producers and thereby dilutes the allocation to the individual plot, as regularly happens with raw material mixes via intermediaries, the purchasing team loses track without initially noticing. If the proof is ultimately missing, the regulation explicitly states that the downstream market participant remains responsible! Therefore, the risk cannot be mitigated solely through trust in the immediate supplier.

To gain a realistic picture of your own supply chain, it is therefore worthwhile to conduct an honest mapping of each raw material: Does your own visibility actually extend to the cultivation area? Does it end with a named cooperative, or does the origin disappear into an irresolvable mixture at a raw material trader?

This allows a purchasing team to gain a reliable overview of its EUDR product portfolio.

To answer the four key questions about your own product landscape in a structured way, the following approach is recommended:

Step 1: Complete and recurring raw material and product mapping

The first step is to systematically check all purchased items against the HS codes in Annex I of the EUDR, across all seven product groups and including their respective derivative products. Each new product must then be checked against these codes and, if necessary, added to the list.

Step 2: Traceability audit for each raw material chain

For each identified raw material chain, it should then be examined how far the actual visibility extends. Specifically, this means documenting for each supply relationship whether geodata is available down to the individual cultivation area, whether the origin only extends to a named cooperative, or whether it disappears into an irresolvable mix at an intermediary.

Step 3: Risk-based prioritization instead of complete coverage at once

To establish a sensible order, it's worth considering two factors: the EU's country benchmarking , which categorizes countries of origin into low, medium, and high risk, and the compliance level of the respective supplier, i.e., registration in the EU information system, existing reference numbers, and available geodata. When both factors are combined, the order becomes clear: products from high-risk countries without reliable supplier verification are checked first, followed by low-risk countries with established suppliers.

Step 4: A mandatory checkpoint before market entry

To ensure that no product enters the EU market without a valid due diligence declaration after the effective date, a clearly defined process step is needed where the due diligence declaration reference number must be available before goods are released or declared for customs purposes. Typical gaps rarely arise on the effective date itself, but rather beforehand: when adding new suppliers or products without EUDR checks, in supply contracts without mandatory updates for changes of origin, or upon goods receipt when reference numbers are not systematically checked against the information system, but only in cases of discrepancies. Firmly integrating this control point into the process prevents a missing declaration from being discovered only at the border.

An EUDR product list is not a document that is created and checked off once, but rather a process that evolves with every adjustment to the scope, every supplier change, and every new batch. Anyone who has only reviewed their portfolio once is working with a snapshot, but without a reliable foundation for December 30, 2026. To help your purchasing team be better prepared, here is a summary of the key takeaways from this article.

• A complete product list includes not only the seven EUDR raw materials, but also their derivative products according to Annex I, and must be updated regularly.

• According to the once-only principle, geodata up to the cultivation area is primarily the responsibility of the first distributor; however, downstream market participants remain responsible if they cannot provide complete proof of the due diligence declaration reference number.

• Not every product and every supplier can be brought to the same level of compliance simultaneously. Prioritizing based on country risk and supplier maturity creates a reliable order before considering full market coverage.

• A mandatory checkpoint before market entry, where the reference number is verified, prevents a missing due diligence declaration from only being noticed at the border. The actual gap usually arises earlier, during supplier and product onboarding or upon receipt of goods.

If you would like to delve deeper into the topic and see possible solutions using a case study, then download our free white paper.