Market note from the Sunex Commodities compliance desk.
The EU Deforestation Regulation places the due-diligence obligation on the operator placing cocoa or coffee on the EU market, usually the buyer. But the buyer can only submit a credible due-diligence statement if the supplier behind it can produce the geolocation and deforestation evidence. The questions below are what a buyer should be able to answer with confidence, and what we, as a supplier, should be able to evidence.
1. Can you give me plot-level geolocation for this lot?
For plots over 4 hectares, EUDR requires a polygon (the boundary of the plot). For smaller plots, a single geolocation point. If a supplier cannot provide this, the lot is not EUDR-ready. Ask for the actual coordinates, not an assurance that they exist.
2. Is every plot in this lot deforestation-free after the cut-off date?
The cut-off is 31 December 2020. The supplier must be able to show that no plot in the lot was deforested after that date. This is checked against satellite mapping, not asserted.
3. Can you issue a due-diligence statement with a reference number?
The DDS is the regulatory document. It carries a reference number the buyer cites when placing the product on the market. A supplier who cannot produce a DDS, or who expects the buyer to assemble it, is not carrying their share of the obligation.
4. What is your risk-assessment and mitigation process?
EUDR expects a risk assessment for the origin and mitigation where risk is not negligible. A supplier should be able to describe how they assess risk per origin and what they do when a plot or a cooperative raises a flag.
5. How do you handle a lot that cannot meet the requirement?
The right answer is: it does not ship against EUDR. A supplier who says "we'll find a way" is a risk. A supplier who segregates non-compliant volume away from EUDR-bound volume is a partner.
6. What evidence do you retain, and for how long?
EUDR requires evidence retention for five years. Samples, geolocation data, risk assessments and the DDS should be retained and retrievable.
What we provide
For every EUDR-bound shipment, Sunex Commodities provides the geolocation data, the deforestation status check, the due-diligence statement with reference number, and the retained evidence trail. The buyer cites our DDS; the evidence behind it is ours to defend.
If you are a buyer and your current supplier cannot answer the six questions above, that is the gap to close before the next shipment, not after a query.
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