Overview

The EU Deforestation Regulation (EUDR) establishes specific requirements regarding mass balance chains of custody, emphasizing traceability and segregation while maintaining practical implementation standards.

Core Requirements

Prohibited Practices

  • Mass balance systems that allow mixing of compliant and non-compliant materials
  • Combining verified materials with unknown origin products
  • Mixing deforestation-free commodities with non-verified materials

Mandatory Elements

  • Traceability to plot of land
  • Physical segregation throughout supply chain
  • Documented chain of custody
  • Verification systems

Implementation Guidelines

Segregation Requirements

  1. Physical Separation
    • Distinct storage areas
    • Separate processing lines
    • Clear material identification
  2. Documentation
    • Source verification records
    • Chain of custody tracking
    • Compliance documentation

Verification Systems

  1. Entry Points
    • Source verification
    • Documentation checks
    • Compliance assessment
  2. Supply Chain Controls
    • Segregation protocols
    • Transfer documentation
    • Verification procedures

Compliance vs. Identity Preservation

Required

  • Plot-level traceability
  • Physical segregation
  • Chain of custody documentation
  • Compliance verification

Not Required

  • Batch-level tracking
  • Individual product tracing
  • Full identity preservation
  • Origin-specific separation

Best Practices

System Design

  1. Clear segregation protocols
  2. Robust documentation systems
  3. Staff training programs
  4. Regular compliance audits

Risk Management

  1. Supplier verification
  2. Material flow monitoring
  3. Documentation reviews
  4. Compliance checks

Frequently Asked Questions

Q: Why are mass balance systems prohibited?

A: They don't guarantee that specific products entering the EU market are deforestation-free since they allow mixing with non-compliant materials.

Q: Is identity preservation required?

A: No, while segregation is mandatory, full identity preservation isn't required.

Q: What does segregation mean in practice?

A: Compliant materials must be physically separated from non-compliant or unknown origin materials throughout the supply chain.

Q: Can I mix certified materials from different sources?

A: Only if all sources are verified deforestation-free and traceable to their plots of land.

Q: Do I need to track individual batches?

A: You need to maintain segregation and traceability but don't need batch-level identity preservation.