Do all goods (imported, exported, traded) have to be traceable?
The traceability requirements apply under the EUDR to each batch of imported/exported/traded relevant raw materials and goods.
The regulations require operators (or traders who are not small businesses) to be able to trace any relevant commodity back to the piece of land it came from before making a relevant product available on the market or exporting it.
This makes the submission of the due diligence declaration, including geolocation data, a requirement for the import of relevant products (customs procedure ‘release for free circulation’) and for export (customs procedure ’export’), as well as for transactions within the market.
How does this work for bulk traded or compounded products?
For products traded in bulk, such as soy, coffee, cocoa or palm oil, this means that the operator (or traders who are not SMEs) must ensure that all plots of land involved in a shipment are identified, and that the goods will not be mixed at any time during the process with goods of unknown origin or from deforested or degraded areas after the cut-off date of December 31, 2020.
For composite products, such as wooden furniture with different wood components, the operator must locate all areas of land where relevant raw materials (such as wood) used in the production process have been produced. The components of the relevant raw materials may neither be of unknown origin nor originate from deforested or degraded areas after the cut-off date.
