EUDR – Pantiko: Forestry App from Logs to Documentation & Prints

The Global Gateway Strategy represents the EU’s commitment to stronger connections with the world through investments in green and digital transitions, higher social and environmental standards, and the creation of more sustainable value chains.

The EUDR (EU Deforestation Regulation) is designed to ensure that certain commodities and products entering or leaving the EU market are deforestation-free and produced in accordance with the laws of their country of origin.
The regulation has two fundamental requirements, while the third—risk mitigation—is directly tied to the first two.

Economic operators are responsible for conducting thorough reviews and analyses of their business activities, which require collecting relevant data, analyzing it, and taking measures to mitigate risks as needed. The risk assessment criteria must be tailored to the specific products intended for the market.

Required information

Data	Art. 9	Risk Assessment	Due Diligence
Description with Commercial and Scientific Name	✓		✓
Quantity of the relevant products (mass, m³, number of units)	✓		✓
Harmonized System code	✓		✓
Country of production	✓	✓	✓
Geolocation of all lands where production took place	✓
Date and time range	✓
Name/Title, Address	✓
Convincing/verifiable information that products do not contribute to deforestation	✓
Convincing/verifiable information that the products were produced in accordance with the legislation of the production country	✓
Respect for national laws	✓	✓
Presence of indigenous peoples		✓
Legislation in compliance with the regulation		✓
Credibility of the data		✓
Corruption, document forgery, etc.		✓
Complexity of supply chains		✓
Risk of evading regulations, mixing relevant products		✓
Additional certification systems		✓

Place and Time of Production

Date refers to the date of harvesting goods (ex: wood)
Time refers to the duration of relevant harvesting processes

Supplier Details:

Name, registered trade name, or trademark,
Address, email, and website of economic operators or traders supplying the relevant products.
Reference numbers of due diligence declarations related to these products.

Geolocation data must be specific (polygons for plots over 4 ha) and and is mandatory also for low-risk countries.

Maintenance of due diligence systems

Annual system review.
Records of updates must be retained for at least five years.
Public reporting.
Findings from risk assessments, including all relevant information and evidence.
Documentation proving that opinions of local communities and indigenous peoples were considered when appropriate.

Definitions and Key Concepts

Placing on the Market
- When a product becomes available on the EU market for the first time
Making Available on the Market
- For distribution, consumption, or use.
- The product must be physically present.
- When customs release it into free circulation.
- Withing the scope of economic activity.
Economic Operator:
- A physical or legal person.
- Responsible for placing products on the market or exporting them.
  - includes nomenclature classifications
  - includes Latin names in case of wood
- Acting within economic activity.

SMEs vs Non-SMEs

Economic operators are classified as:

SMEs (Small and Medium Enterprises).
Non-SMEs.

If SMEs are responsible for the first placement of goods on the market, they must comply with all obligations under the regulation.

Non-EU operators must ensure due diligence is conducted and an EU-based economic operator (with EORI) is responsible for compliance when importing goods into the EU. In this case first company from EU must also create DDS.

Weak Points

In the supply chain, two weak points are expected:

First market entrants (e.g., forest owners), who must provide the majority of required data (Article 9).
Intermediaries, who purchase from such owners and are often SMEs, need to supplement the system with data such as the Harmonized System, additional measurement units, and production time.

Economic operators who are SMEs have some advantages if they are not placing goods on the market for the first time:

They are exempted from the reporting obligation
If they only sell to individuals AND in case they are not placing goods on the market for the first time they don’t need to create new DDS

Mixed Goods

Technical and organizational issues arise in the processing and trading due to mixing of goods (ex: pile of roundwood logs, lumber or silo with soy). This usually involves constant dailly supply and sale processes, often running 24/7, 365 days a year.

Origin of Mixed Goods:
For example, a silo containing goods from multiple sources. If part of this enters the EU, all inputs to the silo since it was emptied must be known and documented.

Manufacturers typically store goods from numerous suppliers, creating significant data requirements.

Example:

One or multiple supplier (SME or not) delivers goods from their warehouse to a manufacturer (e.g., fiberboard)

supplier has to gather all origins of goods that were in their warehouse and provide them to manufacturer
manufacturer must get all this data from supplier

Image below demonstrates possible example of only part of required data for single origin (ex: forest or soy field).

Image below demonstrates single DDS number. It is possible that 100s of these might be needed and must be passed from supplier to manufacturer which will in turn have to input them to EU system.

This demonstrates the need for a system that maximally automates data movement and oversight.

Requirements for Non-SMEs

The highest requirements apply to companies that are not SMEs.

The regulation requires large companies to ensure the reliability of all data, including:

Detecting deliveries lacking required data before mixing with other supplies.
Responsibility remains with non-SME companies or those introducing goods to the market for the first time:
- Ensuring accuracy and reliability of data.
- Cross-checking data via satellite and forest imagery.
- Full accountability for the compliance of all parcels linked to the provided geolocation.

Expected Challenges

Significant pressure from non-SME companies on their suppliers.
Lack of information from the first market entrants:
- Forest owners may not be promptly informed.
- Government institutions might not fulfill their roles.
- Non-EU countries may delay responses.
Potential amendments to the regulation.
Ensuring compliance with national laws, a core requirement of EUDR.
Timely detection of “illegal goods.”
Protection of supplier data.
Integration of EUDR systems into existing systems.

Pantiko

Pantiko Company offers a system for both SMEs to meet the demands of large companies requiring supplier data and non-SMEs to accept this data and incorporate them to their existing systems.