Almost ready for EUDR: Inside our compliance preparations for this monumental legislation

As we approach the implementation of the European Union Deforestation Regulation (EUDR) on December 30, 2025, we recognize the importance of keeping you informed about our preparations.  

Our EUDR journey began by initiating a two-phase project in early 2023. The first phase assessed our readiness and identified gaps. Now, in the second phase, we are implementing a management system to ensure compliance, meet customer expectations and legal obligations, and demonstrate thorough risk assessment and due diligence. Dedicated teams are working on each commodity impacted, including cocoa & chocolate and palm oil.

Our comprehensive approach to demonstrate EUDR compliance encompasses five key areas:

• Establishing a robust system to manage and document due diligence processes;
• Ensuring precise geolocation data;
• Enhancing traceability in both inbound and EU domestic supply chains;
• Preparing and submitting detailed due diligence statements as required and;
• Conducting ongoing monitoring and verification to ensure continuous compliance. 

To give you a clearer picture of the specifics of our approach, “Co-Creating Growth” sat down with David Maton, EUDR Cocoa and Chocolate Project Lead and James Ede, EMEA Sustainability Lead to gain insights into how Cargill is preparing to meet the EUDR requirements.

What are the main challenges that EUDR presents for Cargill? 

David: The EUDR implementation presents several key challenges. First ensuring compliance, requires precise geolocation data across all relevant supply chains, which is particularly complex given the large number of smallholder farmers we collaborate with. Second, enhancing traceability in both inbound and EU domestic supply chains demands significant investment in technology and processes. The ambiguity surrounding the interpretation and practical implementation of the legislation makes it complex. We are proactively addressing these challenges with a clear and adaptive approach to ensure effective planning and implementation. 

James: Another challenge lies in the submission of Due Diligence Statements (DDS) through TRACES, the EU’s official platform for submitting DDS. The system must accommodate a wide range of actors including importers, downstream producers, and retailers. Each actor has different data requirements and operational contexts.

It must have been quite a challenge considering that you have such a broad portfolio and scale? 

James: Indeed. What makes Cargill unique is that we are active in multiple parts of the supply chain, from cocoa farming to butter/powder production, and chocolate production to gourmet decorations, as well as palm oil sourcing and refining, and soy processing. Because of our legal entity structure, we often face the same regulatory and operational challenges as our customers. As a result, we are working towards a true “vertical solution” for the industry with its suppliers. 

David: Yes, it is a challenge due to the breadth of our operations across commodities and geographies. To meet the EUDR requirements we are scaling up our mapping efforts at the farmer level, which is essential for building accurate, verifiable supply chain data. At the same time, we are collaborating with local governments and competent authorities to test and refine traceability tools through dry runs, ensuring they are both practical and robust. We are also working closely with ICE-CoT to help facilitate a smooth and compliant flow of goods through the ‘terminal market’. 

Will Cargill be EUDR compliant on December 30, 2025? 

David: Yes. Our supply chains will meet the EUDR requirements when the regulation takes effect. Cargill shares the European Union’s vision of combating deforestation and forest degradation which aligns with our commitment to transparency and traceability.

We are currently in a transition period until the regulation is fully applied at the end of the year. There are still external factors in the origin countries and open questions remaining on the interpretation and practical implementation of the legislation. We continue to work via our sector associations on these practical elements to help create clarity ahead of implementation.  

James: Our long-standing commitment to sustainability in the food supply chain ensures that we are well-positioned to support our customers through this transition period and deliver compliant products from 30 December 2025 onwards. 

What measures does Cargill have in place to mitigate risks of deforestation in its supply chains? 

David: To be successful in mitigating risks of deforestation in the supply chain, a key focus should be on Monitoring & Evaluation of the first-mile. This includes all actors of the first-mile supply chain including farms, farmers, and mills. Ensuring accurate collection of data is key to identifying risks and following through with mitigation. Cargill collects validated geospatial data from all relevant products entering the EUDR supply chain. Risk assessment is part of our standard process, based on EUDR requirements, including geolocation data, production time range, EC benchmarking ratings, presence of forests, prevalence of deforestation, grievances, and external certification results. If any risk assessment reveals high or non-negligible risk of non-compliance, we have a “ranking” and “prioritizing” process which aims to bring the risk to “negligible.”

How and when will the Due Diligence Statement (DDS) be provided to customers?  

David: “We expect the DDS reference number and verification number to be provided to the customer by e-mail as a PDF attachment, in parallel with product delivery. The verification code number is considered “confidential” as together with the “reference number” it will provide access to the contents of the DDS. This solution is “universal” and can be used by large and small customers, and can be automated if required. In parallel, Cargill is actively collaborating with industry stakeholders to help establish a standardized method for sharing data.

What is happening throughout this transition period? 

James: We are dedicated to supporting our customers throughout this transition. Cargill's extensive experience in applying due diligence across multiple supply chains and geographies uniquely positions us to manage the requirements of the EUDR effectively. The relationships and experience acquired through our long-standing partnerships with customers, industry associations, NGOs, and our suppliers make us an ideal partner for ensuring a transition towards deforestation-free products.