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Ten mistakes we keep seeing in EUDR programmes

Drawn from operational projects where the same pattern repeats: the regulation is understood, and the process still fails.

9 August 2026 · 9 minute read

The regulation is not the hard part. Most teams understand what is being asked of them within a fortnight. What goes wrong is operational, and it goes wrong in the same ten ways.

  1. 01

    Starting with the SKU count

    Two thousand products sounds enormous and is usually irrelevant. The number that determines your workload is how many distinct suppliers those products come from, because every one is a separate conversation.

  2. 02

    Treating scope as a one off exercise

    Someone spends three weeks classifying products, produces a spreadsheet, and then the Annex changes. Scope is a standing process, not a project phase.

  3. 03

    Building the submission before the collection

    The interesting engineering is the declaration. The work is getting evidence out of suppliers. Teams routinely build the first and discover the second has no owner.

  4. 04

    Asking suppliers for everything at once

    A twelve field form covering four products gets abandoned. Ask for what you need for the products you actually buy this quarter.

  5. 05

    Sending a PDF and hoping

    A form attached to an email produces attachments back, in whatever format the sender had. Someone then retypes them, and now your evidence has a typo in it.

  6. 06

    No owner per exception

    A list of two hundred problems with nobody named against them is a list that does not shrink. Every outstanding item needs a person, not a team.

  7. 07

    Chasing manually

    Reminders sent by a human are sent when the human remembers. A supplier who has gone quiet for eleven days is the one you most need to hear from, and the least likely to be top of anyone’s mind.

  8. 08

    Discarding failed uploads

    If a supplier file fails validation and disappears, you have created a dispute. Keep it, show it to them, explain what is wrong.

  9. 09

    Reporting percentages upward

    Eighty seven per cent ready tells a board nothing and tells a buyer nothing. The useful output is which orders can move this week and which cannot.

  10. 10

    Leaving the audit trail until last

    Reconstructing who decided what, when, and on which version of the rules is not possible after the fact. It is either recorded as you go or it is gone.

Sources

  • Regulation (EU) 2023/1115
  • Observations from operational supply chain projects, PainKiller Consulting Group

General information, not legal advice. Requirements change. Verify against the current official text before acting.

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