Preparing for EUDR: What you and your customers need to know during the transition period

With the European Union Deforestation Regulation (EUDR) application date approaching on December 30, 2025, businesses across the supply chain are preparing for a major shift. At Cargill, we’re committed to helping you stay ahead, by working diligently to align sourcing and production processes with the EUDR requirements and by equipping you with the information you need to remain confident.

In our previous newsletter, we shared insights from David Maton, EUDR Cocoa and Chocolate Project Lead, and James Ede, EMEA Sustainability Lead, on how Cargill is approaching EUDR readiness. In this edition, we continue the conversation by addressing some of the most frequently asked questions we’ve received, many of which we know our customers are also hearing from their own stakeholders. These insights give you direct access to the knowledge and guidance that can support your journey towards compliance. 

Can you explain how Cargill tracks each product through the supply chain from origin to delivery?

David: Absolutely. For all relevant products produced by Cargill, we’ve completed a detailed supply chain mapping exercise. This allows us to identify every intermediary and processing stage involved in the journey of each product. Because our supply chains vary depending on the commodity, country of origin, and sustainability expectations, we operate multiple models tailored to these factors. With this approach we intend to trace products with precision and to meet both regulatory and customer expectations under the EUDR. 

Will Cargill’s customers receive a Due Diligence Statement (DDS) for each delivery, or is it issued per batch of product?

James: The Due Diligence Statement (DDS) is issued per batch of product. If a batch is sold in multiple shipments, we’ll resend the DDS information for each transaction to our customers. This ensures traceability and consistency across the supply chain. We expect the DDS reference number and verification number to be provided to our customers by e-mail as a PDF attachment, in parallel with product delivery.

As we move closer to the EUDR application date, customers are looking for clarity on how transitional stocks are handled. One common example: “I buy ingredients in December, produce in January, or export/re-import after the deadline. How do I know if I need to provide full due diligence”?

David: It depends on whether the product and/or the relevant commodity it was produced from was placed on the EU market before December 30, 2025. The European Commission’s guidance document outlines the key principles and here’s how we interpret them across two main scenarios: 

• #1: Customer buying from Cargill in the EU for domestic shipment within the EU. 
• #2: Customer is buying from Cargill in the EU, the product will be exported by Cargill outside the EU to the customer, and then the customer will re-import the end product back into the EU. 

Ok, so tell us what you need to do in Scenario 1 – a customer buys from Cargill in the EU for domestic shipment within the EU…

David: If you’re sourcing EUDR-regulated commodities, such as cocoa, palm, or soy or derived relevant products from Cargill within the EU, the key question is when such commodities or products were placed on the EU market.  

There are three phases to this: 

1. Before the EUDR application date: Products are customs cleared and placed on the EU market by Cargill. You as the customer can place the purchased product and/or your final product on the market after the application date without carrying out due diligence and without submitting a full DDS.  
2. By the EUDR application date: Cargill will complete a full inventory of EU stock and prepare a Due Diligence Statement (DDS) (to be utilized after the application date). This DDS will clearly stipulate that this material is part of the transition stock. You should also complete your own inventory and retain supporting documents (e.g. invoices, contracts, bill of lading). 
3. After the EUDR application date: For deliveries after the deadline, Cargill will provide the DDS reference number and verification number. You need to create your own DDS for your final products covered by the EUDR before placing them on the EU market or exporting them.

And what about the more complex Scenario 2 where the customer is buying from Cargill in the EU, the product will be exported by Cargill outside the EU to the customer, and then the customer will re-import the end product back into the EU…

David: This scenario is indeed more complex, but the same principle applies: if the product was placed on the EU market before 30 December 2025, it qualifies as transition stock and can be re-imported without full due diligence. Cargill awaits clarity on the communication of the “conventional DDS reference number” for products falling in the transitional period, by the EU Commission.

Here’s what that means across the different phases: 

1. Before the application date: Products are customs cleared and placed on the EU market by Cargill, and Cargill prepares an export DDS for transition stock at the point of export to receive a so called conventional DDS reference number. As a non-EU customer receiving these products, you must request (from Cargill) and retain this conventional DDS reference number, and ensure segregation of this material covered by such DDS reference number from other stock without DDS reference number. 
2. By the application date: Cargill completes a full inventory and prepares the export DDS, linking each batch to a conventional DDS reference number. You continue to maintain documentation and segregation of compliant material. 
3. After the application date: When re-importing, you must provide the conventional DDS reference number and proof of segregation to your EU customer. The EU customer must then submit an import DDS, referencing the original export DDS and confirming that the material remained compliant by way of segregation. 

Last but not least, will Cargill sign up to customer data platforms where DDS numbers can be transmitted, such as TradeAware, Osapiens, or Prewave?

James: At this time, due to the large number of different platforms and the lack of standardization among them, we are unable to provide DDS numbers through these channels.  

As we move closer to the EUDR application date, Cargill remains committed to transparency, traceability, and delivering compliant products. We understand that every business has unique needs, and your account manager is your key contact for product-specific questions or documentation requests. We’ll continue sharing updates and insights to support your journey toward compliance.

Disclaimer: The information contained herein is believed to be true and correct at the time of issuance. It is not, and should not be construed as, a guarantee or warranty, nor a part of our contractual or other legal obligations. Please note that the information provided herein is for general informational purposes only and does not constitute legal advice. Each customer remains solely responsible for fulfilling their own obligations under the EUDR. We encourage our customers to consult with their legal and compliance teams to assess their specific responsibilities under the regulation.