On 4 May 2026, the European Commission published updated guidance and implementation clarifications for EU Deforestation Regulation (EUDR), including revised FAQs and proposed refinements to product scope. The update gives organizations greater direction on how the regulation will be applied in practice – while reinforcing that the time to prepare is now.

Importantly, the core legislation has not been reopened, and the implementation timelines remain unchanged; 30 December 2026 for large and medium-sized organizations and 30 June 2027 for most small and micro enterprises.

What has changed is clarity.

For many organisations, this marks a shift from planning to execution. While further regulatory clarifications or adjustments may still emerge, the core EUDR framework is now sufficiently defined for organizations to begin operationalising compliance. The period of waiting has largely passed and the focus now turns to readiness and compliance execution.

What changed—and what didn’t

The updated guidance and FAQs are intended to make EUDR more practical to implement.

Key clarifications include:

• More detailed definitions of roles across the supply chain (operators vs downstream actors)
• Simplified obligations for some downstream operators and traders, including reduced due diligence requirements where DDS information is already available upstream
• Additional guidance on product scope and applicability
• Further guidance on due diligence expectations for low-risk sourcing scenarios and substantiated concerns

At the same time, the core requirements remain unchanged:

• Implementation timelines remain fixed
• Due diligence remains mandatory
• Organizations must still demonstrate traceability and audit-ready proof of compliance

Importantly, while some downstream requirements have been simplified, the burden on first operators remains significant—particularly around transaction-level traceability, due diligence statement (DDS) management and demonstrating compliance through trusted operational data

Why this matters now

EUDR is not simply a sustainability reporting requirement —it is an operational supply chain and market access challenge.

Organizations that cannot demonstrate compliance risk:

• Losing access to the EU market
• Regulatory penalties, product confiscation and fines of up to 4% of EU turnover
• Supply chain disruption and sourcing delays
• Increased operational, financial and reputational risk

At the same time, the regulation introduces a level of operational complexity that many organisations are not yet equipped to manage.

Why EUDR is difficult in practice

While the regulation itself is relatively clear, executing against it requires organizations to build new operational capabilities—often across fragmented systems and complex supplier networks.

Supplier data collection

EUDR requires detailed information from suppliers, often beyond direct tier one relationships. Collecting, validating and maintaining this data across regions introduces significant operational complexity.

Transaction-level traceability

Organizations must track materials across multiple tiers of the supply chain and movement across suppliers and products - while maintaining a clear link back to origin at plot level.

DDS management

Organizations need to generate, submit, retain and link due diligence statements to operational supply chain data – ensuring that processes are repeatable, consistent and audit-ready.

Deforestation-risk assessment

Traceability alone is not enough. Businesses must assess and monitor whether sourcing is linked to deforestation, based on geolocation data and evolving environmental conditions. For many organizations, these requirements create significant operational challenges across supplier data collection, geolocation verification, risk assessment and ongoing compliance management.

This is not something that can be managed through spreadsheets or disconnected reporting processes.  This is where technology becomes essential.

Many EUDR approaches focus primarily on supplier declarations or standalone reporting workflows. EUDR, however, ultimately requires organizations to connect traceability, risk intelligence and operational supply chain execution.

Enabling EUDR compliance with SAP Green Token and LiveEO

Addressing EUDR requires organizations to connect traceability, due diligence and risk management directly into operational supply chain processes—not manage them through disconnected reporting workflows.

SAP Green Token helps organizations address EUDR requirements through:

• ERP-connected, transaction-level traceability across complex supply chains – from plot of land through production processes to finished goods placed on the market
• Connection of sustainability and operational data within existing ERP business processes
• Automated DDS workflows, including integration with regulatory systems such as EU TRACES and exchange of supplier and risk information with risk management systems
• Audit-ready documentation and traceability records

To align with the latest EUDR guidance, SAP Green Token will also streamline TRACES interactions by focusing them on inbound delivery workflows where required for EUDR compliance, no longer requiring TRACES interactions for outbound fulfilment flows.

By connecting sustainability, compliance and operational data together, organizations can move from manual, fragmented approaches to trusted scalable traceability and compliance workflows.

Complementing traceability with deforestation risk intelligence

Traceability alone is not enough. Organizations must also assess and monitor deforestation risk linked to sourcing locations over time.

This is where geospatial intelligence capabilities from partners such as LiveEO provide complementary value.

Through its TradeAware solution, LiveEO uses satellite-based remote sensing and geospatial analytics to help organizations:

• Assess and monitor deforestation risk at plot level through ongoing satellite-based risk intelligence
• Support supplier onboarding, plot data collection and geolocation validation
• Provide risk indicators and supporting evidence for due diligence workflows

Rather than operate as a separate reporting layer, this approach helps connect external risk intelligence with traceability and compliance processes.

A stronger end-to-end approach

Together, SAP Green Token and LiveEO’s TradeAware help organizations connect transaction-level traceability, DDS execution, supplier onboarding and deforestation risk intelligence into a more complete operational approach to EUDR compliance.

Planned API integrations (targeted for end Q2 2026) are intended to help connect risk insights directly into operational compliance workflows

By combining operational supply chain data with external risk intelligence, organizations can move beyond fragmented reporting processes toward more scalable, audit-ready compliance workflows.

What organizations should do now

With timelines confirmed and expectations clearer, organisations should focus on practical next steps:

• Identify impacted products and suppliers across in-scope commodities
• Assess traceability maturity—can materials be traced to origin at transaction level?
• Review DDS processes—how are statements generated, managed and retained?
• Evaluate risk-data requirements—how will deforestation risk be assessed and monitored?
• Align operational teams early across procurement, sustainability, compliance and IT

The priority now is execution.

Learn more: Join our upcoming webinar

EUDR ultimately requires organizations to build audit-ready supply chains—connecting traceability, risk intelligence and operational workflows.

To explore these challenges in more detail, join SAP and LiveEO for our upcoming webinar on 28 May, where we will discuss practical steps organizations can take now to prepare for EUDR.

Learn more about:

• SAP Green Token: SAP Green Token
• EUDR background and requirements: What is EUDR?