Key Facts
- What should come before selecting software?
- A needs assessment of your own supply chain: scope of raw materials, supplier structure, data maturity, and internal resources
- What is the biggest obstacle to implementation?
- It is not a lack of software features, but rather unclear responsibilities, unstructured communication with suppliers, and a lack of ERP integration
- How should the rollout proceed?
- In five steps: needs assessment, selection based on integrability, structured data collection, pilot phase, rollout with integration into day-to-day operations
- What exactly does the lawcode EUDR module do?
- AI-powered risk analysis, interactive mapping feature, multilingual supplier self-service portal, ERP integration, and direct interface to the EU information system
- How can we measure the success of the pilot phase?
- Supplier response rates, the quality of the submitted geodata, and the internal coordination effort between Purchasing, Compliance, and IT
- What safeguards does the module provide for data processing?
- GDPR compliance, ISO 27001 certification, and a legal review by the law firm Taylor Wessing
Summary for Decision-Makers
Even the best software is of little use if its implementation isn’t well thought out. Ultimately, it’s not the tool itself that determines success, but how well the underlying process is set up: who is responsible within the company, how suppliers are integrated, how clean the data is in the end, and how well the whole system interacts with procurement and the ERP system.
This is exactly where many companies run into problems in practice. The software has been selected, but then suppliers don’t get back to them, no one really knows whether the procurement or compliance department is responsible, and in the end, there isn’t enough data to prepare a legally compliant due diligence statement.
Those who plan for this from the outset—with a realistic assessment of their own supply chain, a manageable test run, and clear accountability for day-to-day operations—will navigate the EUDR implementation much more smoothly. Instead of constantly grappling with manual tasks, you make a one-time investment in a well-designed process. And as a bonus, this creates something that remains useful beyond the EUDR: a solid foundation of supplier and geodata that can also serve as the basis for other due diligence or ESG obligations.
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A Brief Overview of the Legal Background
To provide some context: TheEUDR requires companies to demonstrate, for certain raw materials, that they do not come from areas that were cleared after the end of 2020. This requires geographic coordinates, a risk analysis, and a due diligence statement in the EU system. The start date has since been postponed twice; it is currently set for the end of December 2026 for large and medium-sized companies, and mid-2027 for small and micro-enterprises. This does not change the actual obligations—only the timeline. And it is precisely this extra time that should be used to tackle the implementation process, rather than simply letting it slip away.
We have summarized all the details about the EUDR—such as its scope, deadlines, and affected product categories—in our article on the basics of the EUDR.
The Five-Step Implementation Process
Needs Assessment: Mapping the Supply Chain and Raw Materials
Before selecting software, it should be clear just how complex your supply chain actually is: How many categories of raw materials are involved, how many tiers of suppliers are in between, and how reliable is the existing data? A company that purchases directly from a small number of producers has different requirements than one with multi-tiered, international supply chains involving intermediaries.
In practice, it’s helpful to conduct a structured assessment based on four questions:
- Scope of raw materials: Which of the seven EUDR raw materials—wood, cattle, cocoa, coffee, palm oil, rubber, and soy—are relevant to your product portfolio, and in what quantities or at which stages of the value chain?
- Supply Chain Structure: Are purchases made directly from producers, or are there one or more intermediary stages involved? The more stages there are, the more important it becomes to determine how far the company’s traceability currently extends.
- Data Readiness: Are there already geodata, certificates, or supplier questionnaires from previous sustainability initiatives that can be reused, or does the data collection process need to be set up from scratch?
- Internal Resources: How much capacity is realistically available in Purchasing, Compliance, and IT for the implementation, and over what time frame?
The outcome of this analysis has a significant impact on how quickly the process can move forward afterward. Those who focus on just a few, clearly defined raw materials can often complete the entire process in a few months. In contrast, with a complex supply chain involving hundreds of suppliers, it’s more realistic to proceed step by step and tackle the raw material categories one at a time.
Ready to tackle the EUDR rollout?
You don't have to start from scratch. With the EUDR module, a 30-minute live demo will show you exactly how geodata collection, risk analysis, and due diligence reporting could work in your company—without your team having to wade through Excel spreadsheets.
Prioritize selection criteria: Integration over feature set
In practice, it’s not so much the number of features that matters, but rather how well a solution integrates into existing workflows. lawcode’s EUDR module is designed precisely for this purpose: It doesn’t function as a separate add-on application, but rather integrates into existing ERP processes. The status of the due diligence declaration is visible directly within the procurement process. Certificates, geodata, and due diligence declarations are automatically consolidated in the supplier profile. This saves the procurement, compliance, and customs departments a great deal of duplicate work.
When evaluating competing solutions, it’s worth considering several aspects at once rather than focusing on a single feature:
- Technical Integration: Can the software be integrated with the existing ERP system, or will it result in an additional standalone solution that must be maintained in parallel?
- Legal Compliance: Has the solution been reviewed by independent legal counsel? lawcode’s EUDR module has been legally reviewed by the international business law firm Taylor Wessing. This aspect is particularly relevant during tax audits.
- Data Security: Since supplier and geographic data are processed centrally across the entire supply chain, GDPR compliance and ISO 27001 certification are not secondary considerations, but rather core criteria.
- AI-Based Risk Analysis: How transparent is the methodology behind the automated assessment of deforestation risks, and can it be documented in a way that is verifiable by regulatory authorities?
- Scalability beyond the EUDR: Can the same data infrastructure be reused later for other supply chain requirements, such as supplier risk management or sustainability reporting, or is this purely a one-off solution?
If you prioritize these criteria over a mere list of features, you’ll avoid unpleasant surprises. After all, some solutions seem to offer a wealth of features on paper but only turn out to be impractical in day-to-day shopping months later.
Data Collection: Structured Collection of Geodata and Supplier Data
The biggest challenge during implementation is usually obtaining geodata from suppliers without straining the business relationship. Lawcode’s EUDR software solves this by:
- Pre-filled questionnaires for each raw material category that suppliers can complete directly through a multilingual self-service portal
- Interactive map feature with a polygon drawing tool that allows crop areas to be drawn directly onto the map and automatically recorded as geographic coordinates
- Automatic Deforestation Risk Assessment by Area Based on AI-Driven Risk Analysis
This creates a low-threshold process for suppliers and provides the company with a structured, verifiable database instead of scattered Excel spreadsheets.
One aspect that is often underestimated in this process is communication with suppliers. Many producers and intermediaries receive similar requests from multiple customers at the same time and are understandably annoyed by the added workload. A self-service portal with a multilingual interface helps tremendously here: The supplier can see at any time what’s still missing and doesn’t have to make a special phone call or send an email, which noticeably speeds up the response rate. Existing certificates, such as those from the Rainforest Alliance, can also be uploaded directly and are automatically assigned to the appropriate supplier profile. This eliminates the need for duplicate data entry.
Important for your own risk assessment:
The recorded geographic coordinates should not simply be collected. The AI-powered analysis automatically compares each mapped area with current deforestation data and assigns it to a risk class. This allows for a more detailed examination of areas that stand out, while areas that do not stand out do not unnecessarily slow down the process.
Pilot phase involving a single raw material category or a supplier cluster
Instead of migrating all raw materials and suppliers at once, it is advisable to conduct a pilot run with a manageable group, such as a single raw material or a region. This allows you to test status tracking, follow-up inquiries, and the quality of incoming geodata on a small scale before expanding the rollout to the entire supply chain.
It is best to establish fixed criteria for the pilot phase rather than tying them solely to a timeframe.
For example:
- How many of the suppliers contacted respond within a certain time frame?
- How much of the submitted geodata passes the automatic completeness check on the first try?
- And how much coordination is actually needed between procurement, compliance, and IT?
These figures provide a fairly accurate indication of how realistically the rollout to other raw materials can be planned and how much time and personnel are actually required for it.
Another advantage: The pilot phase quickly yields tangible results that can be effectively communicated internally. And if the EUDR implementation involves multiple departments, a visible initial success—such as a fully documented raw material category—makes it much easier to gain buy-in for the next, larger rollout steps.
Rollout and Integration into Day-to-Day Operations
Following the pilot phase, the focus shifts to preparing complete due diligence declarations for the EU information system. Lawcode’s EUDR module automatically checks the data for completeness beforehand and submits it directly via an interface. This eliminates the need for manual uploads. In addition, ongoing supply chain monitoring runs in the background, functioning like an early warning system: this allows new risks to be identified even before the next due diligence check is due.
Three things are crucial for ongoing operations after the rollout.
- First: Who will be responsible for maintaining supplier data going forward—Purchasing or Compliance? This should be clearly defined so that new suppliers are included from the very beginning.
- Second, it’s worth checking the risk ratings regularly, because the risk of deforestation in a given area can change over time.
- And third, the interface with the EU system should be integrated into the existing internal approval processes, rather than functioning as an isolated, additional step alongside the other compliance approvals.
Real-World Example
A company with a multi-tiered cocoa supply chain is beginning its implementation with this very raw material. Suppliers in Ghana receive a pre-filled questionnaire via the self-service portal, map their cultivation areas using the mapping feature, and the system automatically assesses the deforestation risk for each area. Initially, about one-fifth of the plots show an elevated risk. The affected suppliers are then specifically asked via the portal to provide additional documentation. Once this pilot phase is complete—including a full due diligence declaration via the EU system interface—the process will continue in a structured manner with coffee and rubber. The lessons learned from the pilot—such as how quickly suppliers responded and how long the processing took—are directly incorporated into the planning of the next steps.
Common Challenges During Implementation
Incorrect jurisdiction: The EUDR is often categorized as a sustainability issue, but at its core it is a requirement under foreign trade and customs law. If its implementation is not coordinated with the customs and foreign trade departments, there is a risk of operational bottlenecks in the TRACES integration.
Unclear data quality among existing suppliers: Historical supplier data is rarely structured in the way the EUDR requires. An automatic completeness check prior to submission—such as the one provided by lawcode’s EUDR solution—identifies gaps before they become a problem for the regulatory authority.
Indirect suppliers (Tier 2+): Even multi-tiered supply chains with upstream intermediaries can be mapped using the module, as long as traceability back to the farm is guaranteed—a factor that companies should explicitly consider when making their selection.
A Wait-and-See Approach Due to the Deadline Extension: The postponed implementation dates may tempt companies to delay the start of the rollout as well. However, since the additional time is needed primarily for data collection and process development, companies that adopt this approach are squandering the very time that the extension was intended to provide.
The Underestimated Effort Involved in Communicating with Suppliers: When a request for geographic data lands in an inbox without any explanation, it can quickly come across as yet another unnecessary bureaucratic hurdle. A structured, multilingual self-service portal that shows progress, on the other hand, is much better received than a casual email request, and the response rate is correspondingly higher.
Lack of Link Between Risk Analysis and Procurement Decisions: If the risk rating of a cultivation area is not fed back into the actual procurement process, it remains merely a documentation artifact. Only when the DDS status is visible within the procurement process itself does EUDR compliance actually influence procurement decisions.
No preparation for follow-up inquiries from the authorities: Even after a due diligence statement has been successfully submitted, an authority may still follow up or request additional supporting documentation. Those who cannot quickly access well-organized documentation—for example, regarding how the risk assessment was conducted—will suddenly find themselves tying up an unnecessary amount of internal time and staff resources.
A Stand-Alone Solution Instead of a Comprehensive Platform: If EUDR software is implemented completely separately from other compliance and ESG issues, multiple parallel systems will eventually emerge, all of which manage—in one way or another—the same supplier data. A solution that integrates into a broader compliance and ESG suite prevents exactly that from the outset.
Conclusion: From Obligation to Competitive Advantage
EUDR software alone does not make anyone compliant. What matters is the path to compliance. Those who treat the implementation solely as an IT project and ignore the organizational issues usually end up with the same result: The software may be up and running, but the process behind it remains bogged down by manual follow-ups, incomplete supplier data, and unclear responsibilities. On the other hand, those who plan the implementation thoroughly from the start—for example, with a needs analysis, a focused pilot phase, and a structured rollout—will benefit from it in the long term. And not just as a one-time compliance exercise, but as a solid foundation for supply chain transparency that will remain useful even after the EUDR.
That is exactly what lawcode’s EUDR solution is designed to do. It brings several elements together on a single platform: AI that automatically assesses risks, a map for plotting cultivation areas, a portal through which suppliers can enter their own data, an integration with the ERP system that displays the status in the purchasing department, and a direct connection to the EU information system. In addition, the solution offers GDPR compliance, ISO 27001 certification, and a legal review by the law firm Taylor Wessing to ensure that data is processed securely and that you are on the safe side when dealing with regulatory authorities. This transforms a tedious obligation into a real advantage for compliance, procurement, and risk management—and the work doesn’t have to start all over again after the first due diligence statement.
And if you start now instead of waiting for the official launch date, you'll simply have more breathing room. You can then tackle the pilot phase and rollout at a leisurely pace, rather than suddenly finding yourself under time pressure right before the deadline.
Frequently Asked Questions
That depends on the complexity of the supply chain. With a focused pilot phase for each raw material category, the basic process can usually be set up within a few weeks before rolling it out to additional categories.
The self-service portal, featuring pre-filled, multilingual questionnaires, significantly lowers the barrier to entry for suppliers. Where gaps remain, the automatic completeness check flags them before submission, allowing for targeted follow-up.
Yes, provided that traceability back to the farm can be ensured. For multi-tier supply chains, a pilot phase is recommended to test the process with intermediaries.
Tools dedicated solely to geodata typically cover only mapping. The EUDR module integrates geodata with risk analysis, supplier management, due diligence, and direct integration with EU systems into a single, end-to-end process.
Yes, a free live demo and a trial version are available so you can test the process—from geodata collection to due diligence—in advance.
No. Since experience has shown that data collection and supplier onboarding take the most time, the implementation should begin early, regardless of the official launch date.
Since the EUDR is primarily a requirement under customs and foreign trade law, responsibility for it should be assigned to those areas—in close coordination with procurement and compliance—rather than resting solely with the sustainability function.
Yes. The module is part of the lawcode Suite for compliance and ESG management and can be integrated with other modules, such as supplier risk management, sustainability reporting, and policy management, so that supplier data does not have to be maintained multiple times in separate systems.
Violations of the EUDR may result in fines of up to 4% of annual revenue generated in the EU, as well as the seizure of the affected products. Since experience has shown that collecting data from suppliers takes the most time, this task should not be put off until just before the deadline.

Karim Boukaouche
LinkedInESG compliance expert - lawcode GmbH
Karim Boukaouche advises companies on the implementation of the EU Deforestation Regulation (EUDR) and supports the implementation of digital solutions for legally compliant supply chains. His specialist articles on the lawcode blog combine regulatory depth with practical recommendations for action.





