The CMS Lisbon office recently hosted an event on the EU Deforestation Regulation (EUDR), bringing together representatives from a wide range of international companies to exchange views on the practical challenges and opportunities arising from the regulation and the European Commission's May 2026 updates. Two key challenges emerged repeatedly during the discussion: Understanding and implementing the recent simplifications introduced by the Commission and communicating EUDR requirements effectively throughout global supply chains.
Navigating Uncertainty Ahead of the EUDR Deadline
As companies continue preparing for the EUDR's expected application at the end of 2026, a key theme of the discussion was the ongoing uncertainty surrounding compliance expectations. Many businesses are still seeking clarity on what will ultimately be required under the EUDR and how competent authorities across different EU Member States will approach audits and enforcement.
Particular attention was given to the simplifications introduced by the European Commission in May 2026. While these changes have generally been welcomed, companies are still working to understand their practical implications. At the same time, the recent relaunch of the TRACES system has required businesses to reassess implementation plans and compliance processes.
Interestingly, even companies that had invested significant resources in preparing for the original EUDR requirements and were already prepared for the EUDR last year are now facing additional challenges: Many of these companies must adapt systems, processes and supplier engagement strategies that had already been designed around the previous framework.
Technology and Human Engagement Must Go Hand in Hand
The discussion also explored the role of technology in supporting EUDR compliance. Solutions such as those provided by LiveEO can play an essential role in helping companies meet regulatory requirements and manage large volumes of supply chain data.
Nevertheless, participants agreed that technology alone is not sufficient. Successful implementation also depends on human engagement: understanding supply chains in practice, maintaining open dialogue with suppliers and customers, and ensuring that all stakeholders understand what is required for compliance.
For many companies, compliance and especially EUDR compliance is no longer primarily a legal exercise. It requires close collaboration with suppliers, customers and other stakeholders to ensure that information can be collected, verified and shared in a practical manner.
Understanding supplier constraints beyond the EU framework
Our colleague, Tatiana Londono, highlighted the importance of recognizing the realities faced by suppliers outside the EU. European companies often assume that documentation, registration systems and certification structures available within the EU exist elsewhere. In practice, this is frequently not the case. This is particularly evident when working with smallholders in sectors such as coffee production, where formal company registrations, certificates or other documentation may not be readily available. As a result, suppliers often require education and support from their European customers to understand what is expected under the EUDR. Building this understanding takes time and sustained engagement.
Using compliance to unlock transparency and collaboration
Despite the challenges, participants also highlighted the opportunities presented by the regulation. The EUDR encourages companies to gain a deeper understanding of their supply chains, strengthen supplier relationships and improve transparency across sourcing networks.
Many organisations reported that the compliance process has already prompted valuable conversations with suppliers and helped identify areas where supply chain visibility can be improved. In addition, EUDR also provides an opportunity to engage with clients and understand better their needs, which may open valuable insights for the business.
Different Approaches Across Member States
Another important topic was the expected variation in enforcement approaches among Member States. As national authorities will be responsible for auditing companies and assessing compliance, businesses are closely monitoring how different authorities interpret and implement the regulation in practice.
Compliance as a Continuous Process
A final conclusion from the event was that the EUDR should be viewed as a compliance journey rather than a destination. Achieving perfect implementation in every aspect may not always be possible, particularly given the complexity of global supply chains. Nevertheless, every step towards greater transparency, traceability and compliance represents meaningful progress and contributes to the overall objectives of the regulation.
As the end of 2026 approaches, companies will need to continue balancing regulatory requirements with commercial realities, while working collaboratively across supply chains to build practical and sustainable compliance frameworks.
Is your company in scope of EUDR?
If you want to know if your company's activities are impacted by the regulation - click the box below to complete your legal check up!
