Implementation roadmap for a grain exporter

This chapter proposes a roadmap in eight workstreams, designed for a Brazilian company that originates, stores, processes and exports soy and its derivatives and that already runs a supplier traceability and socio-environmental compliance programme.

26.1 Workstream 1 — Governance

• Appoint a board-level sponsor and an executive owner for the EUDR, mirroring the "compliance officer at management level" that non-SME customers are required to have (Article 11(2)).
• Set up a cross-functional committee: origination, sustainability, legal, commercial/export, logistics/warehouses, industrial operations, IT and quality.
• Approve a deforestation- and conversion-free origination policy with a cut-off date of 31/12/2020, aligned with the EUDR and with customers' commitments.
• Define a responsibility matrix for each stage of the lot's journey.

26.2 Workstream 2 — Scope of products and customers

• List every exported product with its tariff code and mark those covered (1201, 1208 10, 1507, 2304) and those not (2106, 2923, 3826 and so on).
• Map EU customers and destinations and each customer's role (operator, downstream operator, trader; SME or not).
• Map the incoterms and identify situations where the company itself or an affiliate would be an operator (importing on its own account, DDP, stock held in the EU, a European subsidiary).
• Identify products sold to European customers out of other countries, which may also be placed on the EU market.

26.3 Workstream 3 — Supplier base and geolocation

• Register 100% of the direct and indirect suppliers of soy with a potential EU destination.
• Collect polygons of the area actually cultivated per harvest (not merely the perimeter of the property), with six decimal digits, checked against the CAR and SIGEF.
• Handle crop rotation and over-declaration within the limits of FAQ 1.18.
• Validate the geometries: overlaps, invalid polygons, points used for areas above 4 ha, swapped coordinates.
• Keep a version history of the polygons and of the collection date.

26.4 Workstream 4 — Deforestation and legality analysis

• Define a documented geospatial method: sources (PRODES, MapBiomas, GFC 2020 v3, TFM 2020, state maps), time window (from 31/12/2020), area thresholds, treatment of alerts and analyst review.
• Adopt the EUDR definition of forest (0.5 ha; 5 m; 10% canopy; predominant use) and not merely the Brazilian legal classification.
• Define the legality file per supplier (Chapter 12) and how often it is refreshed (at least each harvest and before any significant purchase).
• Record the risk conclusion per plot and per supplier, with the date, sources and the person responsible — the same logic the authorities will require of the importer (Article 10(4)).

26.5 Workstream 5 — Physical segregation and stock control

• Design the EUDR flow in the warehouses: dedicated silos, intake windows or FIFO with a 200%-of-capacity control.
• Block loads from ineligible suppliers or areas in the intake system.
• Control inputs to continuous crushing by period.
• Control the logistics through to the port, shared terminals and transhipment included.
• Audit the segregation periodically.

26.6 Workstream 6 — Data pack and customer contracts

• Standardise the EUDR pack per lot: GeoJSON, eligibility reports, legality declaration, a description of the control system and the direct supplier's data.
• Define the technical delivery channel and the access policy (data protection included).
• Negotiate clauses: the scope of the information, delivery deadlines before shipment, confidentiality, use restricted to EUDR purposes, cooperation in checks and substantiated concerns, liabilities and caps.
• Prepare for the 30/12/2026 turn: identify contracts whose customs clearance is expected after that date.

26.7 Workstream 7 — Non-compliance, complaints and reinstatement

• A procedure for the immediate blocking of a supplier or plot once risk is identified.
• A procedure for notifying the European customer of new information affecting lots already sold (the customer has a duty to inform the authority — Article 4(5)).
• A grievance channel and an investigation process with deadlines.
• A reinstatement protocol: an area deforested after 31/12/2020 stays non-compliant; reinstatement applies to the producer, with geometric and documentary segregation of the compliant fields, never to the converted plot itself (FAQ 1.15).

26.8 Workstream 8 — Training, audit and continuous improvement

• Train originators, graders, warehouse operators, the commercial team and suppliers.
• Commission an independent audit of the system, mirroring what non-SME customers must have.
• Review the system at least once a year (Article 12(2)) and after regulatory changes.
• Track the milestones: the Commission's repositories (Dec. 2026), revision of the country list, the authorities' annual reports (30 April) and the Commission's summary (30 October).

26.9 Suggested timetable up to application