This spring, the NVWA conducted trial inspections at companies with products that fall under the EUDR. Important insights have emerged from these so-called dry runs that may be significant for other companies also falling under the EUDR. Does this apply to you? Then you can use this information in your preparation.
Collaboration with the Business Sector
During the trial inspections, we collaborated with companies from various sectors that were already far along in their preparations for the EUDR. Companies voluntarily signed up for this process, where we particularly sought collaboration with importers of relevant raw materials. Together we examined what works well and where there were still shortcomings to comply with the law.
Complying with the EUDR
This page is a supplement to other information. Also, see how to establish a system of due diligence requirements for the EUDR and how to make the EUDR a fixed part of your business operations. Not sure what the EUDR means for you? Then use the regulatory assistance and see what applies in your situation.
Insights and Tips
Below are a number of things that stood out to us during the trial inspections. You can use this in your preparation for the EUDR.
Due diligence is more than collecting information
In the EUDR, it states what information must be collected and which risks must be assessed. This can be found in articles 9 and 10. However, during the trial inspections, it became clear that much of the collected information was not always assessed for risks. Consequently, no actions or measures were linked to it. This is mandatory according to the law.
Platforms can support but not replace
Various companies use platforms or software for the EUDR. These platforms can support your system of due diligence when used correctly. Platforms are useful for, for example, collecting information or assessing risks. However, this information or risks must still be further assessed and weighed within your company. Also, ensure that the platform substantiates claims with relevant documentation or other forms of evidence. Your company remains responsible for conducting due diligence. A platform cannot replace this.
Certification does not replace due diligence
Certification is not the same as conducting due diligence. You can use certification as a risk-mitigating measure. You can only implement this when you know exactly which risk you are mitigating with the certification. For example, purchase certified products and clearly indicate how the certification contributes to reducing the risk.
Due diligence works better as an integral part of business operations
We found that due diligence systems that are well integrated, for example, in purchasing, sales, and inventory management, function better than systems that are separate from these. Companies that have incorporated due diligence into their operations are often more successful in ensuring compliance with the EUDR requirements.
Due diligence is necessary for all requested subjects
Certain sectors already have much experience with conducting due diligence on topics characteristic of that sector, such as human rights or deforestation. For the EUDR, it is expected that you pay sufficient attention to all requested subjects; the previously done work can help you with this.
Linking the physical product to the location of origin
If it is established that a product from a certain location meets all EUDR requirements, it is important that the product you physically market in Europe is verifiably the same product. You must be able to guarantee traceability and that it originates from the same location. We have seen that for most companies it was possible to source products from deforestation-free locations.
More Information
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