How Rigorous will EUDR Enforcement Be? Recent Dutch, German Investigations Reveal Strict DDS Review

Recently the German and Dutch government conducted dry runs of EUDR enforcement in order to meet the law's hefty audit targets (9% of shipments from high-risk countries, 6% from standard-risk, and 3% from low-risk.) Their findings underscore the importance of scalable solutions with a robust audit trail. The greatest challenges for companies lie in implementing geospatial traceability and establishing a systemic, evidence-based due diligence process.

Key Findings of the EUDR Reports

The tests conducted by the German Thünen Institute (RiMoDi project) and the Dutch Food and Consumer Product Safety Authority (NVWA pilot inspections) highlight the necessity of advanced technology and rigorous internal processes for compliance.

🇩🇪 German Report (RiMoDi Project)

The German project focused on developing a risk-based monitoring tool to support the federal inspection authority (BLE) in verifying compliance.

Geospatial Monitoring is Essential: The primary finding is the necessity of developing a robust GIS-analysis tool that combines satellite imagery (Copernicus Sentinel data) with cloud-based processing to check for deforestation and forest degradation at the specific plot of land.
Risk-Based Control: The system is designed to provide authorities with risk information and maps, allowing for efficient, targeted, and tiered checks—from quick verification of large data sets to detailed single-case examinations.
High-Tech Requirement: Compliance is fundamentally dependent on an objective, high-tech method for verifying that the exact coordinates of the sourcing land are deforestation-free.

🇳🇱 Dutch Report (NVWA Pilot Inspections)

The Dutch "dry runs" with advanced companies revealed critical gaps in how due diligence is currently practiced.

Due Diligence Must be Actionable: The most common failure was treating due diligence as a mere data collection exercise. Companies often failed to properly assess the risks based on the collected information and did not establish subsequent actions or mitigation measures, which is mandatory.
Technology is a Support, Not a Replacement: While many companies used software platforms, the NVWA stressed that the platform does not replace the company's responsibility. The company must still internally assess, weigh, and substantiate the platform's risk estimates with proof.
Certification is Not Due Diligence: Certifications (e.g., FSC, RSPO) are useful only as one component of a risk-mitigation plan, not as a substitute for the entire due diligence process. The specific risk being mitigated must be clearly defined.
System Integration is Key: Due diligence systems that were integrated into core business functions (like procurement, sales, and inventory) functioned better than standalone systems, highlighting the need for compliance to be systemic.
Preventing Commingling: Companies must map risks at processing sites (e.g., mills, refineries) to ensure the final product entering the EU is not mixed or "commingled" with materials from non-compliant locations, requiring end-to-end traceability.
Traceability to the Physical Product: A clear, verifiable chain of custody is needed to guarantee that the physical product placed on the market is demonstrably the same product sourced from the compliant, deforestation-free location.

Sourcemap's Positioning for EUDR Compliance

Sourcemap is best positioned to assist companies because its platform directly addresses the core, complex requirements highlighted by both the German need for geospatial verification and the Dutch need for systemic, automated due diligence.

EUDR Compliance Challenge	How Sourcemap Assists Companies
Geospatial Traceability (Thünen/NVWA)	Sourcemap specializes in mapping supply chains to the farm or polygon level, collecting the precise latitude and longitude coordinates and Declaration of Due Diligence (DODD) data required for every shipment under the EUDR.
Active Risk Assessment (NVWA)	The platform automates the plot-level risk analysis. It can ingest the required coordinates and instantly check them against satellite data and official risk benchmarks (like the future EU registry or external tools like RiMoDi) to provide a verified, auditable risk score for every shipment.
Preventing Commingling (NVWA)	Sourcemap maps the end-to-end chain of custody, including complex processing and intermediate facilities (e.g., refineries). By tracking inputs and outputs at these critical mixing points, it helps companies demonstrate that the final product's volume and mass are free from commingled, non-compliant materials.
Systemic Integration (NVWA)	As an enterprise-grade platform, Sourcemap integrates the entire due diligence system—from supplier onboarding to final audit report—into a company's existing ERP, procurement, and inventory systems, making compliance a systemic business function rather than an isolated, manual effort.
Documentation and Audit Trails (NVWA)	The platform automatically collects, verifies, and stores all required documentation (DODDs, evidence of legal compliance, risk assessment reports, mitigation measures) in a single system, creating a clear, auditable trail that can be presented to authorities to avoid costly penalties (fines up to 4% of EU turnover).