Executive Summary
This guide outlines requirements and procedures for handling products containing non-compliant components under the EU Deforestation Regulation (EUDR).
Core Requirements
Non-Compliant Component Management
- Identification Requirements
- Locate all non-compliant components
- Document identification process
- Verify separation possibilities
- Separation Procedures
- Physical removal of non-compliant parts
- Documentation of separation process
- Verification of complete removal
Mixed Product Implications
Automatic Non-Compliance Triggers
- Mixing with non-compliant materials
- Contamination from unknown sources
- Loss of traceability
- Incomplete separation
Bulk Commodity Considerations
- Single non-compliant plot affects entire batch
- No partial compliance possible
- Complete batch rejection required
Compliance Requirements
Product Acceptance Criteria
- Traceability
- Plot-level identification
- Complete supply chain documentation
- Verification records
- Legal Status
- Compliance with local laws
- Deforestation-free verification
- Documentation of legal status
- Segregation
- No mixing with non-compliant materials
- Maintenance of separation
- Verification protocols
Implementation Guidelines
Prevention Strategies
- Supply Chain Controls
- Strict segregation protocols
- Verification at each stage
- Documentation systems
- Risk Management
- Supplier verification
- Regular audits
- Compliance monitoring
Remediation Options
- Before Mixing
- Component identification
- Physical separation
- Verification procedures
- After Mixing
- Product rejection
- Documentation requirements
- Reporting procedures
Frequently Asked Questions
Q: What makes a product non-compliant?
A: Any component that can't be traced to its plot, was produced on deforested land after 2020, or has been mixed with non-compliant materials.
Q: Can I salvage part of a mixed product?
A: No, once non-compliant materials are mixed with compliant ones, the entire product becomes non-compliant.
Q: What about bulk commodities?
A: If any source plot is non-compliant, the entire batch becomes non-compliant if materials have been mixed.
Q: How can I ensure compliance?
A: Maintain complete traceability, ensure legal sourcing, and prevent any mixing with non-compliant or unknown origin materials.
Q: What documentation is required?
A: Records showing traceability to plot level, legal compliance, and segregation maintenance throughout the supply chain.