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The EU Deforestation Regulation will fundamentally change how companies source commodities and proactively assess their supply chains for compliance. Industry experts from Ferrero, Preferred by Nature and Sourcemap discuss what to expect as we approach the EUDR enforcement deadline, and how to prepare for what's coming. Speakers Floriane Hédé, Traceability Manager, Responsible Sourcing at Ferrero Christian Sloth, Director, Sustainability Programme at Preferred by Nature Marissa Brock, Sr. Director of Policy and Government Affairs at Sourcemap 1. Initial Reactions to the Potential 12-Month Delay Political Compromise: The delay (which would shift the enforcement date to December 30, 2025) is seen by Christian Sloth as a political compromise to limit opposition and allow the current regulatory language to pass. A Necessary Breather: Drawing on the experience of the earlier EU Timber Regulation (EUTR), where neither authorities nor industry were ready at the start, the delay is viewed as potentially positive. It gives companies time to align and prevents initial enforcement from being "lax." Enforcement Will Be Strict: Both panelists agree that if the delay is confirmed, companies shouldn't relax. Competent authorities will use the extra 12 months to ensure they have the mechanisms and processes in place to enforce the regulation strictly from day one. 2. Lessons from the EU Timber Regulation (EUTR) Christian Sloth highlighted that the EU learned several key lessons from the EUTR that are reflected in the EUDR's design: Improved Enforcement Mechanism: The EUDR addresses past issues with lack of alignment and data sharing among Member States by implementing the EU Traces database to collect customs data. Extended Liability: The liability for due diligence is extended downstream in the supply chain and to the point of export, making it harder to bypass requirements using "strawman companies." Executive Buy-in: For companies, implementation must be taken at the executive level with sufficient resources. In the past, compliance was often assigned to buying/selling staff who lacked the necessary expertise and power. 3. Ferrero's Proactive Approach and Strategy Florian Edd explained that Ferrero, a long-time leader in responsible sourcing, is well-prepared for the EUDR but is using the potential delay strategically: Current Pace Maintained: Ferrero is maintaining its current speed of preparation as if the original December 30, 2024, deadline were still in effect. Prioritization: Traceability efforts initially focused on key ingredients by volume (hazelnuts, cocoa, palm oil, dairy) but have now been adapted to include smaller-volume UDR commodities like coffee. Strategic Use of Delay: Any extra time will be used to optimize data transfer between internal systems, partners like SourceMap, and external monitoring platforms like Starling (used for satellite monitoring of palm oil), as well as to leverage forthcoming APIs to automate processes. Overcoming Supplier Reluctance: Ferrero manages supplier concerns about data confidentiality or being bypassed by relying on its public Supplier Code (which requires agreement to transparency) and by spending significant time clarifying ambitions to build trust. 4. Compliance Challenges and Best Practices Legality Ambiguity: While the EU will release country benchmarks for deforestation risk, Christian Sloth noted these may not fully address the legality aspect, which remains a core requirement. Companies cannot rely solely on the Commission to answer every question but must proactively conduct robust risk assessments. Commodity Readiness: The Timber sector has a "jump start" due to its EUTR experience. Other sectors like Cocoa, Coffee, and Palm Oil have strong sustainability precedents, but those with historically complex or small-holder-driven supply chains may face unique challenges in collecting consistent geolocation data. The 12-Month Opportunity: Companies should use the extra time to pre-screen all consistent suppliers for both deforestation and legality compliance, and begin remediating identified risks before the law takes effect. Role of Auditing: On-the-ground audits are an important risk mitigation measure, especially in high-risk areas where documentary evidence alone is insufficient to verify compliance with certain legal requirements (e.g., health and safety on farms). 5. Conclusion and Call to Action Ferrero's Commitment: Ferrero remains fully supportive of the EUDR, believing it provides a clear framework for a notion (traceability) that can otherwise be vague. Collaboration is Key: Christian Sloth emphasized that compliance hinges on collaborating and establishing relationships with suppliers, as due diligence on non-certified chains is impossible without trust and openness to information sharing. Action Now: Companies must proceed as planned; the delay is an opportunity for preparation, not a break.