EUDR and the Agrisector of Ukraine: Ensuring Compliance, Transparency and Access to the EU Market

In collaboration with I.P.Cert, the Ukrainian Agribusiness Club (UCAB) hosted an online seminar dedicated to the practical aspects of implementing EU Regulation 2023/1115 (EUDR) for Ukrainian soybean producers, processors and exporters.

The online seminar was attended by agrarians, exporters, government representatives, as well as compliance and certification specialists. The event aimed to clarify the new requirements for exporting agricultural products to the EU and provide businesses with the tools they need to adapt to European sustainability standards.

Significance and nature of the EUDR for the Ukrainian agrisector

The EUDR Regulation is the EU’s response to global environmental challenges. The objective is to reduce deforestation, preserve biodiversity and lower greenhouse gas emissions. It establishes criteria for accessing the EU market, including: the absence of any link to deforestation after 31 December 2020; compliance with land, environmental, tax and labour legislation during production; and the full documentation and control of processes involving commodities such as soy, cocoa, palm oil, beef, coffee, timber and their derivatives.

The EUDR has the following implications for Ukrainian exporters of soybeans and soybean products:

• a ban on exports of products grown on deforested land after 31 December 2020
• the need to confirm the legality of land use and compliance with environmental, labour, anti-corruption and other standards
• the requirement for full traceability of each batch to a specific plot of land through geolocation coordinates and systematic audits.

Although Ukraine has been granted low-risk country status, which simplifies certain procedures, the requirements for geodata collection, documentation and control remain. For Ukrainian agribusinesses engaged in trade with the EU, compliance with EUDR becomes a mandatory obligation and a crucial factor in building trust with European partners, opening the door to premium contracts and long-term cooperation.

Documentation and digital traceability 

Under EUDR, precise geolocation coordinates must be collected for each production field (up to 4 ha — centroid; over 4 ha — polygon with at least 4 points). While cadastral numbers are not mandatory, their presence strengthens legal certainty and simplifies audits. All information on suppliers, fields, volumes, delivery dates, production legality, and environmental compliance must be stored for a minimum of five years.

Each batch is assigned a unique identifier, facilitating tracking from field to warehouse and export. The documentation includes land rights extracts, lease agreements, certificates, self-declarations of compliance with environmental, labour, and anti-corruption laws, tax clearance certificates, and satellite monitoring results.

Digital traceability systems (electronic logs, QR codes, integration with TRACES NT) significantly simplify audit preparation and enhance trust among European partners.

Internal control, audit and risk management

The control system introduces “red flags” to identify discrepancies: deforestation, legal violations, uncontrolled mixing of compliant and non-compliant products. Selective physical audits of suppliers have become standard, with frequency depending on supply chain risk (20% to 100% annually).

All supply chain participants must implement internal controls to swiftly provide documents upon request by auditors or regulators. Engagement of external auditors, consulting companies and centralised digital platforms are recommended for complex supply chains to automate processes and increase transparency.

A risk-based approach optimises audit costs by implementing basic controls for simple chains, multi-level monitoring and external audits for complex ones. Special attention is required for mixed batches, where the “200% principle” applies – all fields potentially supplying raw materials must be declared.

Readiness for inspections and interaction with the authorities

Agricultural producers and exporters must be able to confirm the origin of each batch, from field to warehouse. All relevant documents and geodata must be organised and made available for inspection by exporters, auditors or the relevant EU authorities for a period of 5 years. The Due Diligence Statement (DDS) is submitted via the TRACES NT electronic platform, which is integrated with EU customs systems.

TRACES NT is a tool for submitting the DDS that contains a digital archive, allowing for quick responses to requests from regulatory authorities and minimising the risk of cargo delays at the border. In the event of violations, products may be withdrawn from the market, fines of up to 4% of the turnover and a temporary export ban may be imposed.

Practical experience and key approaches from the Market Guide

The Market Guide developed by UCAB and I.P.Cert provides detailed algorithms for implementing traceability systems, document templates, geodata examples, and instructions for organising internal control and audits. Various traceability models are described, ranging from the most stringent (preserving the identity of each batch) to a clustered and centralised digital platform.

• IP model (Identity Preservation): maximum transparency, premium contracts, highest level of trust.
• Batch model: flexibility for elevators and large traders, controlled mixing of compliant batches with full documentation.
• Cluster model: optimal for cooperatives and agricultural holdings, centralised control and simplification for small producers.
• Centralised model: national digital platform for automated traceability, reduced manual work, and enhanced transparency.

Use of international certification schemes (ISCC, Donau Soja, Europe Soya, ProTerra) increases trust in Ukrainian products but does not replace the obligation to provide full documentation and traceability.

Conclusions

Compliance with EUDR is a complex process that requires a systematic approach to geodata, documentation, internal controls and cooperation across the supply chain. Failure to comply can result in the loss of EU market access and financial penalties. Ukrainian agribusinesses that implement digital accounting systems, train staff, use official guides and engage consulting partners will gain a competitive advantage in the European market. Implementing EUDR builds trust with European partners, ensures export stability and promotes the sustainable development of Ukrainian agrisector.

BDO in Ukraine supports agribusiness in times of change: business process automation, audit, accounting — all to ensure transparency and compliance with EU market requirements. Contact us to ensure your business remains competitive and prepared for new challenges.