The European Commission has published a third edition of the EUDR Supply Chain Infographics: Understanding Your Position in Beef, Cocoa, Coffee, Palm Oil, Rubber, Soy, and Wood Supply Chains, clarifying how the EU Deforestation Regulation (EUDR) applies across commodities.

The guidance distinguishes between “upstream operators”, who must carry out due diligence before placing products on the EU market, and “downstream operators and traders”, whose obligations focus on traceability and record-keeping.

Within this context, most leather manufacturers and tanneries would typically be downstream operators, provided the cattle (and hides) are already covered by due diligence upstream. For cattle, upstream operators must ensure products are deforestation-free, including demonstrating production has not taken place on land deforested after December 31, 2020.

Downstream actors are not required to repeat due diligence but must retain and share due diligence statement (DDS) references. The guidance also requires full traceability to production plots and prohibits mixing with non-compliant or unknown-origin materials.

Simplified requirements are introduced for small primary producers in low-risk countries, who can submit a one-time declaration instead of full due diligence.

Read the full infographic here.