EUDR
EU Deforestation Regulation

Despite the extension, urgent action is required because:

• Without a timely due diligence statement (DDS) in TRACES, affected goods may not be placed on the EU market or exported.
• If a DDS with geolocation is required, this cannot be achieved with C3 processes alone; the implementation of a comprehensive due diligence system is also necessary.
• Our internal resources for updates and implementation are limited (see section 5).

Important: According to the current legal situation, manufacturers from non-EU countries must always submit an extended DDS including geodata if they wish to place products on the market in the EU.

With this regulation, the European Union has introduced new due diligence requirements. These may include the implementation of a comprehensive due diligence system. In most cases, at least a digital due diligence statement must be submitted to the EU information system.

The exact requirements depend on the type of company, its position in the supply chain, its size and the country of origin of the raw material.

Therefore, check in advance what role you play (market participant, trader) and whether you meet the conditions for SMEs. Please note that the role may vary depending on the business process and that, even if you are considered an SME, you may have a different role with extended due diligence obligations due to your position in the supply chain.

For more information, see "Helpful resources" in section 7.

The regulation covers seven raw materials and numerous products made from them:

• Wood (including paper, pulp, furniture, books, etc.)
• Soy
• Natural rubber
• Beef & leather
• Palm oil
• Coffee
• Cocoa

The products affected are listed in Annex I of the EUDR.

After goods receipt, the reference and verification numbers provided by the supplier can be entered and assigned. This can be done either manually or fully automatically via Papinet messages. Assignment takes place at the role/batch and delivery note position level – however, for better usability, the data is summarised and displayed at the position level. The numbers can be checked via the C3 TRACES interface at the touch of a button. In goods issue, the products to be delivered are aggregated at delivery note position level and new reference and verification numbers are generated (if necessary) at the touch of a button via the TRACES interface.

Requirement for automatic, consistent number flow between goods receipt and goods issue is active single role or batch management in C3. If you do not yet use this, please plan an implementation project in good time.

➡️ Note: The EUDR functionality is only available in the latest version of C3.2020. Please check which version you are using and whether you need to upgrade to C3.2020.

• End of June 2025: Completion of the C3 update
• July 2025: Start with 2-3 test customers – please get in touch if you are interested!
• Please note: Our resources for updates, upgrades and implementation are limited. We operate on a first-come, first-served basis, as we will probably not be able to accommodate all requests, especially during the peak months of November and December.

1. Clarify role status (market participant/trader) and check SME classification if applicable.
2. Identify affected articles.
3. Create a TRACES account (if you have not already done so).
4. Adapt processes and software – activate or introduce role/batch management.
5. Apply to become a pilot customer.

There are numerous resources and sources of assistance available for the EU regulation. The Federal Agency for Agriculture and Food (BLE), as the implementing agency, lists many webinars and recordings as well as documents and articles on its website:
✅ Bundesanstalt für Landwirtschaft und Ernährung (BLE)

The BLE offers free initial advice in conjunction with the Business & Human Rights Helpdesk:
✅ Helpdesk on Business and Human Rights

In addition, information on the regulation on deforestation-free products can also be found on the European Commission's website:
✅ EU Commission: Regulation on Deforestation-free Products

Julian Auerbach
Head of Customer Satisfaction Management
Email: j.auerbach@theurer.com
Phone: +49 7141 / 79155‑91