EUDR

The EUDR is expected to come into force on 30th December 2025, after which the listed commodities will need 
to be proven to be deforestation-free in order to be placed, made available or exported from the EU market.

Commodities included: Cocoa | Coffee | Soy | Cattle | Palm Oil | Rubber | Wood 

1. They have not been produced on land deforested or degraded after 31 December 
   2020 (traceability + geodata)
2. Have been produced in accordance with the relevant legislation of the country of 
   production (includes forest rules, right to land & other relevant legislation)
3. Are covered by a due diligence statement - this statement will have to disclose that 
   due diligence was carried out and that no, or only negligible, risk was found at an 
   “adequately conclusive and verifiable” level

As some EU Guidance is still pending, subject matter experts within ECOM closely follow any 
updates & official guidance from the EU, and our EUDR process will be amended accordingly.

An updated set of FAQs is expected, but timelines from the EU are unclear.

ECOM’s EUDR Risk Assessment relates to the Article 10

• ECOM has utilized publicly available indicators from international and reliable 
  sources to determine the risks in our supply chains.
   
• EUDR Risk Assessment Methodology is complementary to other ECOM policies 
  and processes, including our Supply Chain Due Diligence process.
   
• At this current stage, we have assigned all origins we source from as “high” or 
  “medium” risk in our country assessments as we prepare for implementation.
   
• These rankings will adjust when the EU publish its country risk assessment, 
  expected in June 2025.

If/when risks are identified, additional steps are taken through our Risk Mitigation 
Process to ensure products are only imported if no or only a negligible risk is achieved.

Our EUDR Risk Assessment process is updated at least on an annual basis, taking 
into account learnings and feedback from internal and external stakeholders, as 
well as relevant guidance from the EU and local governments. 

• Ensures that the relevant products are sourced from areas where deforestation 
  or forest degradation has not taken place after December 31, 2020.
   
• Verifies that local relevant legislation(s) have been adhered to in the production 
  of the relevant products (such legislations including land use rights and 
  environmental protection).
   
• Tests and confirms the reliability and validity of the information provided by our 
  suppliers, including the information in the due diligence statements.

ECOM’s Risk Mitigation approach is formed from preventative, detection and corrective 
measures, such as : 

• Contractual assurances including our Supplier Code of Conduct
• Preassessment of suppliers’ practices, incl. EUDR compliance, and data collection through Sourcemap self assessment or data capture via BanQu in the direct supply chain
• Sensitising suppliers and farmers to upcoming requirements
• Conducting risk-based checks and audits

We assess the complexity of our relevant supply chains by looking into many components including 
but not limited to: 

• the type and number of actors involved, level of processing of the product and any certifications 
  held
• Additionally, we use yield control mechanisms and supplier assessments to further manage 
  complex sourcing risks

We will continue to communicate any changes in the legislation in order to help clients and suppliers 
prepare for the future.

• Our grievance mechanism (Speak Up Policy) is open and accessible by all stakeholders
• If you have any questions or concerns, please do not hesitate to contact your Supremo contact or 
  esgcompliance@ecomtrading.com

ECOM developed its own deforestation assessment tool as the industry standard 
methods were not accurate in measuring deforestation with tree crop agriculture
Replanting and pruning of crop trees is often incorrectly identified as deforestation. 

ERDA uses radar data which is : 

• Unaffected by clouds
• Able to penetrate through the tree canopy
• Able to measure the underlying biomass
• Thus, able to distinguish between forest and crop pruning, etc.
• This reduces the number of misclassified deforestation events
   

ERDA uses radar data to measure live woody biomass, and a leading UK university has validated the method.
Industry standard methods to measure deforestation in the tropics were not designed for the purpose of assessing individual farms across a multitude of different origins. 

The Deforestation Verification Protocol (DVP) establishes a standardized, Group-wide procedure for verifying the legitimacy of 
deforestation flags identified by ERDA. 

• The DVP comprises four stages, with the initial two conducted at the desktop level and the latter two at the farm level.
• Each stage uses different methods to assess whether the farm was under managed agricultural use before the cut off date
• At each stage, the assessor may conclude the evaluation if negligible risk is confidently determined, otherwise they will 
  escalate to the following stage
• Each stage requires photographic evidence and completed survey which are saved and stored for 5 years
• Feedback from deforestation events and false positives is integrated into future development of ERDA