Why an Integrated Operational Approach Is Essential
Preparing for Regulation (EU) 2023/1115 (EUDR) and Regulation (EU) 2024/3015 (EUFLR) is often treated as two completely distinct projects. In operational reality, however, the legality due diligence requirement of the EUDR strictly mandates proof that commodities were harvested in compliance with national labor laws and fundamental human rights standards.
Structuring these compliance workflows in unison allows your team to engage suppliers once, collect data in a standardized schema, and eliminate duplicate audit expenses.
Step 1: Unified Supplier Intake Questionnaire
Rather than sending disconnected questionnaires, deploy a unified intake assessment split into three connected sections:
- Section A: Facility and Plot Identification
- Registered business name, address, and VAT/tax registration details.
- GPS coordinates (single point for plots < 4 ha, or full polygon boundaries for plots $\ge$ 4 ha) for EUDR compliance.
- Total headcount of permanent, seasonal, and contracted workers.
- Section B: Labor Standards & Recruitment Practices (EUFLR)
- Details on the use of third-party recruitment agencies and confirmation of the Employer Pays Principle (workers do not pay hiring fees).
- Written confirmation that workers retain full, unhindered access to their identity documents and passports.
- Verification of formal employment contracts written in a language understood by the employees.
- Section C: Local Legal Compliance Dossiers
- Identification numbers and expiration dates of harvesting, logging, or agricultural operating licenses.
- Documented proof of social security contributions, tax filings, and minimum wage adherence.
Step 2: Conducting Joint On-Site Audits
When scheduling internal quality reviews or commissioning third-party social audits (e.g., Sedex SMETA or amfori BSCI), update the audit scope to cover both regulations in a single site visit:
- During Social Reviews: While reviewing payroll ledgers and conducting confidential worker interviews, auditors can simultaneously verify facility and parcel boundary GPS coordinates to ensure they match declared production sites.
- Sub-tier Facility Reviews: Inspect intermediate storage and processing hubs for labor compliance while verifying that compliant raw material batches are physically segregated from non-certified stocks.
Step 3: Unified Supplier Agreement Terms
Integrate comprehensive sustainability terms into standard procurement contracts:
- Data Delivery Milestones: Suppliers must provide complete geolocation packages, operating licenses, and labor compliance declarations at least 5 business days prior to dispatch.
- Verification Rights: The buyer reserves the right to withhold shipment acceptance if origin coordinates fail TRACES NT validation (EUDR) or if unmitigated forced labor risks are identified within the supplier's hiring channels.
Step 4: Structuring a Unified Lot Dossier
Maintain a single digital folder for every incoming commodity shipment containing:
- Commercial invoice and transport documents (CMR/Bill of Lading).
- TRACES NT Due Diligence Statement (DDS) reference number.
- Validated GIS file containing plot coordinates.
- Recent third-party social audit report or verified fair labor declaration.