The EU Deforestation Regulation has gone through delays, amendments and implementation guidance, but its core commercial message has stayed the same. For products in scope, the supply chain has to support due diligence with information that reaches back to origin.
That makes it a supplier-selection issue. A factory may make an acceptable finished product and still lack reliable information about the relevant raw material. If traceability is only requested after the order, the supplier may have no practical way to reconstruct it. Before the purchase order, we would work through these steps:
- Establish whether the commodity and product code are covered.
- Confirm which operator carries the obligation.
- Define the evidence needed for the actual product. This does not mean collecting every possible document from every supplier.
- Test the supplier's evidence before committing volume. The answer has to be more specific than 'materials from an approved source'.
- Check that the information can travel with the commercial order.
A clear requirement at enquiry stage costs far less than a compliance investigation after arrival.