akar.earthEUDR vs CSDDD Supply-Chain Duties
EUDR vs CSDDD supply-chain duties: product-based deforestation rules versus company-wide due diligence, and what Indonesian suppliers will be asked.
The EUDR is a product rule: for seven commodities and listed derived products, every shipment placed on or exported from the EU market must be deforestation-free, legal and covered by a due diligence statement. The CSDDD (Corporate Sustainability Due Diligence Directive) is a company rule: large companies must identify, prevent and address human rights and environmental harms across their chain of activities. Indonesian exporters of palm oil, coffee, cocoa, rubber or wood will face EUDR data demands per shipment and broader CSDDD-driven questions about labour, land rights and environmental impacts.
Side-by-side comparison
| Attribute | EUDR | CSDDD |
|---|---|---|
| Legal form | Regulation (EU) 2023/1115, directly applicable | Directive (EU) 2024/1760, transposed by member states |
| Unit of obligation | Each product placed on or exported from the EU market | The company and its chain of activities |
| Who is covered | Operators and traders of covered commodities, any size | Large EU and some non-EU companies above thresholds |
| Scope of issues | Deforestation, forest degradation (wood), legality in country of production | Human rights and environmental adverse impacts broadly |
| Commodities | Cattle, cocoa, coffee, oil palm, rubber, soya, wood and derived products | All sectors |
| Key evidence | Plot geolocation, cut-off check (31 December 2020), legality, risk assessment | Risk mapping, prevention plans, grievance handling, stakeholder engagement |
| Output | Due diligence statement per placement | Company policies, actions and reporting |
| Mass balance | Not accepted | No product traceability rule as such |
| Timing | The Commission states it applies from 30 December 2026 | Application delayed and phased after 2025 simplification; check current text |
| Enforcement | Competent authorities, checks, penalties, market exclusion | National supervisory authorities; civil liability provisions subject to amendment |
Key differences
Product versus company. Under the EUDR, an operator cannot place a non-compliant batch of coffee on the market, however good its policies are. Under the CSDDD, the question is whether the company runs an adequate due diligence process across its operations and business partners. See operators and traders.
Breadth of issues. The EUDR covers deforestation and legality, though “legality” includes land use rights, labour, human rights and the principle of free, prior and informed consent where relevant under national law. See legality requirement. The CSDDD covers a broad list of human rights and environmental impacts, beyond forests.
Proof. EUDR proof is data-heavy and specific: coordinates, polygons for plots over 4 ha, satellite checks, a due diligence statement. CSDDD proof is process-heavy: policies, risk assessments, corrective action and grievance mechanisms.
Stability of rules. Both have shifted. The EUDR application date has been postponed before; the Commission now states 30 December 2026, with later changes possible, especially for micro and small operators. The CSDDD was amended through the EU Omnibus simplification process. Check the application date page and current EU sources.
When each fits in Indonesia and Southeast Asia
- Palm oil, coffee, cocoa, rubber and wood exporters to the EU: expect EUDR data requests from EU buyers for every shipment. See the EUDR hub.
- Suppliers to large EU brands in any sector: expect CSDDD-style questionnaires on labour, land conflicts, community consent and grievance handling.
- Smallholder supply chains: both laws converge on smallholders. Plot registration and documented consent serve both; see farmer registration and consent.
- Carbon project developers: not directly in scope, but corporate buyers may apply CSDDD-style due diligence to project partners and land rights.
Cost and effort considerations
We do not quote costs. Effort drivers:
- EUDR: polygon mapping, satellite screening, legality documentation, data transfer to buyers. Use the EUDR readiness check.
- CSDDD-driven requests: social audits, grievance mechanisms, human rights risk assessments and supplier codes.
- Reuse: one supplier register with plot IDs, owner identity, consent records and land documents serves both. That avoids repeated village visits and survey fatigue.
Our EUDR compliance service builds that register.
Questions to ask your EU buyers
- Which law drives the request? EUDR data is shipment-specific; CSDDD questions are about your company and suppliers.
- What format do they need? Agree on polygon formats, plot IDs and document lists before field collection starts.
- How often will data be refreshed? Both laws expect ongoing monitoring, not a one-off submission.
- Who pays for the data work? Clarify cost sharing early, especially where smallholders and intermediaries must be mapped.
Common misconceptions
- “CSDDD replaced the EUDR.” They are separate laws with separate obligations.
- “Small exporters are outside both.” They may be outside CSDDD scope, but EU buyers will still request EUDR data.
- “A certificate covers both.” Neither law accepts a certificate as automatic proof.
- “Human rights are only a CSDDD issue.” EUDR legality includes relevant human rights and land-rights laws of the producing country.
Back to the EUDR hub.
Frequently asked questions
Do companies covered by CSDDD still need to comply with the EUDR?
Yes. The two laws apply in parallel. The EUDR governs specific commodities placed on the EU market; the CSDDD sets broader company-level due diligence duties. Compliance with one does not discharge the other.
Does the CSDDD apply directly to Indonesian suppliers?
Not directly, unless an Indonesian company meets the scope criteria for non-EU companies. In practice, EU customers in scope pass due diligence expectations down the chain through contracts and questionnaires.
Has the CSDDD been changed since adoption?
Yes. The EU's 2025 Omnibus simplification work changed timing, thresholds and some obligations. Check the current consolidated text and national transposition laws rather than older summaries.
Is the EUDR a directive or a regulation?
The EUDR is a regulation, so it applies directly across the EU. The CSDDD is a directive, so each member state must transpose it into national law.