EUDR for an SME outside the EU: what an exporter must supply to its European customer

The EUDR applies to the operator that places a product on the European market — not directly to a producer or exporter located outside the Union. In practice, however, it is the latter who holds the information needed for the statement its European customer must file. This guide is aimed at non-EU suppliers who receive an EUDR compliance request without always understanding why it is addressed to them, when they are not themselves subject to the regulation.

Why your customer approaches you when the regulation does not target you

The regulation requires the European operator to prove, for each product placed on the market, the absence of deforestation on the plot of origin after 31 December 2020. Yet this information — the precise geographical coordinates of the plot — exists nowhere on the European side: it exists only where the product was grown or harvested, that is, with you. Without it, your customer simply cannot file its statement, however rigorous its own organisation may otherwise be.

What a European customer actually asks for

1. The GPS coordinates of each plot that produced the exported material, in decimal format, recorded in the field rather than estimated.
2. A statement of the date the plot was brought into cultivation or use, making it possible to check that it was already in use before 31 December 2020 — or, if it is more recent, proof that no deforestation preceded its cultivation.
3. Clear traceability between the plot and the exported batch — what volume from which plot went into which shipment, on which date.

You do not need an expensive system to respond

Supplying this information does not mean investing in dedicated software from the first shipment:

• A GPS reading with a smartphone is enough for the precision required by the regulation — no professional equipment is needed for a plot of standard size.
• A simple spreadsheet linking each exported batch to its plots of origin covers most of the traceability requested, as long as the volume remains manageable by hand.
• A cooperative or producer group, if one exists in your supply chain, can pool this collection for all its members — see our guide on the EUDR for coffee and cocoa for the details of this approach.

What changes if you process the material before export

An exporter who processes the raw material before shipping it (roasting, sawing, primary processing) becomes the reference point of the entire traceability chain for its European customer: it is your internal traceability, linking the plots of origin to the processed batches exported, that becomes the central piece of the file — not just the raw coordinate record.

Common mistakes

• Thinking the request stems from an arbitrary demand by the customer rather than from a legal obligation that weighs on it — understanding where the request comes from helps you respond proportionately rather than perceiving it as unjustified mistrust.
• Supplying an approximate coordinate in the belief that precision is not checked — see our guide on satellite monitoring to understand why it is.
• Waiting for the customer's request rather than anticipating the collection, which delays each new shipment until the information is ready.

Checklist

1. Record the GPS coordinates of each productive plot, in the field.
2. Document the date each plot was brought into cultivation or use.
3. Keep a spreadsheet linking each exported batch to its plots of origin.
4. Check whether a cooperative or group in the supply chain already offers pooled collection.
5. Prepare this documentation before the customer's request, not after.