Preparing for EUDR together: What the latest updates mean for you

With the application of the European Union Deforestation Regulation (EUDR) approaching on 30 December 2026 for large and medium operators, businesses across the supply chain are moving closer to implementation.

Recent updates from the European Commission, including additional guidance and a simplification package, are helping bring further clarity on how the regulation will work in practice. The EUDR aims to prevent products linked to deforestation from entering the EU market, covering key supply chains such as cocoa, coffee, timber, palm oil, and soy.

Cargill shares the European Union’s objective of combating deforestation and forest degradation linked to the production of agricultural commodities and products, and this work aligns with our ongoing efforts to strengthen transparency and traceability in our supply chains.

As implementation approaches, many customers are asking what these updates mean in practice. Below, we outline the most important developments and what you can expect as we move toward December 2026.

What has changed and what it means for the supply chain

The European Commission’s latest simplification package is designed to make EUDR implementation more practical, while maintaining its objective of preventing deforestation-linked products from entering the EU market. One of the most significant changes is a shift in how due diligence responsibilities are applied across the supply chain.

“Under the proposed simplification package, duplication of due diligence is significantly reduced by assigning primary responsibility to the operator placing products on the EU market,” explains James Ede, EMEA Sustainability Lead.

This also impacts the role of downstream operators. Under the current proposed framework, only the first downstream operator in the EU is required to retain the Due Diligence Statement reference number (DDS RN), rather than repeating due diligence at multiple stages.

The European Commission continues refining implementation guidance and the EU Information System (EUIS), meaning some operational aspects are still being clarified.

What this means for you

For most EU customers, the current proposed simplification is expected to reduce administrative complexity.

In most cases, Cargill is expected to be in the role of the operator placing products on the EU market, and in the role of the first downstream operator (as the result of producing new products). Here:

• Most customers are not expected to receive a DDS reference number with their shipments.
• The need for customers to carry out due diligence activities are eliminated.
• Existing DDS sharing practices if required are expected to remain largely unchanged.

“In practice, this means a clear simplification for the majority of EU customers,” says David Maton, EUDR Lead.

A key factor is how products are processed. Where products are transformed and their customs tariff code changes, the DDS reference number would generally not need to be passed on downstream.

There are, however, some exceptions:

• If goods remain under the same customs tariff code.
• Or if the customer is identified as the first downstream operator.

In these cases, a DDS reference number will be provided and must be retained.

If you do not receive a DDS reference number, this typically indicates, under the current proposed framework, that you are not considered the first downstream operator.

This approach reflects the current simplification package.

What you can expect from Cargill

Cargill continues to align its sourcing and production processes with EUDR requirements, with the objective that relevant supply chains will meet these requirements when the regulation takes effect on 30 December 2026.

We are strengthening systems and processes across our supply chains, including:

• Traceability and supply chain mapping.
• Supplier engagement and due diligence processes.
• Geolocation data collection and validation.
• Internal systems to support Due Diligence Statement submission.

If a DDS reference number needs to be shared, it will be provided as a PDF via email at the time of product delivery, starting from the application date.

We also continue to actively engage with industry associations and EU authorities to help inform practical implementation as guidance evolves.

Specific scenarios to be aware of

In certain cases, additional considerations apply.

For example, if products are exported from the EU and later re-imported, the original DDS reference number or export documentation can be used to demonstrate compliance. Customers must also confirm that handling of the product has remained consistent with EUDR requirements.

Cargill maps product flows to ensure clarity on roles and responsibilities across supply chains, particularly in more complex scenarios.

Moving forward together

The EUDR represents an important step toward more transparent, deforestation-free supply chains. While the latest updates provide greater clarity and simplification, guidance continues to evolve and some questions remain.

At Cargill, we remain committed to:

• Supporting our customers through this transition.
• Providing clarity as additional guidance becomes available.
• Continuing to align our sourcing and production processes with EUDR requirements.

We will continue to monitor developments closely and share updates as we move closer to implementation. If you have questions about what these updates may mean for your business, please contact your account manager.

 

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Disclaimer: The information contained herein is believed to be true and correct at the time of issuance. It is not, and should not be construed as, a guarantee or warranty, nor a part of our contractual or other legal obligations. This content is provided for general informational purposes only and does not constitute legal advice. Each customer remains solely responsible for fulfilling their own obligations under the EUDR. We encourage customers to consult their legal and compliance teams to assess their specific responsibilities under the regulation.