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Technology Solutions for EUDR Compliance
If your business exports beef, timber, or any of the seven covered commodities into Europe, you have a regulatory deadline: 30 December 2026. From that date, every shipment needs a Due Diligence Statement filed to TRACES NT — the EU's central compliance system — before the product crosses the border. No DDS reference number, no market entry. This is the EU Deforestation Regulation: Regulation 2023/1115, amended by Regulation 2025/2650.
Country risk benchmarking is part of the regulation: the Commission classifies origin countries as LOW (1% check rate), standard (3%), or HIGH (9%). Classification waives some redundant risk-assessment steps for LOW-risk sourcing but does not waive geolocation, traceability, or DDS submission obligations. The European Parliament voted in July 2025 to object to the benchmarking methodology — a non-binding political signal, not a legal change — while the Commission reviews methodology. Non-compliance carries fines of up to 4% of annual EU-wide turnover, confiscation of product, and public naming of the infringement.
Brainstack Technologies has built this type of system. Offline-first PWAs for smallholder GPS data collection in rural Africa (deployed with COSA in Burundi). Sentinel-2 satellite verification pipelines. ERP integrations that trigger compliance workflows from purchase orders. TRACES NT DDS submission orchestrated via AWS Step Functions. Engineering delivers from Delhi NCR with Melbourne coordination for AU clients. The architecture diagram further down this page shows exactly how the pieces connect.
Enforcement Timeline (Regulation 2025/2650 — confirmed December 2025)
- 30 December 2026: Large and medium operators must be fully compliant. Due Diligence Statements submitted via TRACES NT before every market placement.
- 30 June 2027: Micro and small operators — additional six-month window.
- 4 May 2026: European Commission published simplification review (COM(2026) 191 final) — confirmed December 2026 enforcement, noted substantial burden reduction for low-risk country sourcing.
- 22 May 2025: Country benchmarking implementing regulation entered force. First classifications published (Australia LOW, Brazil HIGH for several commodities, Indonesia HIGH for palm oil and timber).
Key Changes Under the December 2025 Amendment
- Downstream operators no longer file separate DDS; first placer on EU market is responsible.
- Country risk benchmarking active: 1% checks (low), 3% (standard), 9% (high-risk).
- Printed products (Chapter 49 CN codes) removed from scope.
- Penalties confirmed: up to 4% annual EU turnover, market exclusion, confiscation, public disclosure.
The Critical Path Is Data, Not Technology
The December 2026 deadline is achievable for organisations that start building compliance infrastructure now. The binding constraint is not building the technology — it is collecting plot-level geolocation data from suppliers. Supply chains with many smallholder producers in low-connectivity areas can take 6–12 months to instrument. Start data collection immediately; build the submission platform in parallel.
Our EUDR Technology Capabilities
01Geospatial Deforestation Verification
EUDR Article 9 requires operators to verify that production plots were deforestation-free since 31 December 2020. We build verification pipelines that ingest plot geolocation, retrieve Sentinel-2 multispectral imagery (10m resolution at bands 4/8 for NDVI; 20m at bands 11/12 for SWIR analysis), and compute vegetation index time-series from January 2021 forward.
The non-obvious constraint: NDVI alone misclassifies cloud shadow and seasonal dry-season browning as deforestation. Our pipelines use SWIR bands alongside NDVI to distinguish real canopy loss from false positives — especially important in West African cocoa regions where persistent cloud cover makes clean composites scarce. Plots that breach the change-detection threshold route to a human review queue with annotated satellite evidence, not automatic rejection.
Discuss Your Verification Approach

02Plot Geolocation & Polygon QA
The EUDR geolocation requirement has a critical threshold at 4 hectares — but with an important exception: this threshold applies only to non-cattle commodities (soy, coffee, cocoa, palm oil, rubber, wood). For cattle, the polygon requirement does not exist at all. Cattle establishments — where animals were held at any point — require only a single geolocation point per establishment, regardless of size. Beef and cattle supply chains therefore design geolocation data collection fundamentally differently from coffee or cocoa builds.
For non-cattle commodity plots above 4 hectares, a complete GeoJSON polygon boundary is required in WGS-84 EPSG:4326 coordinate system, minimum 6 decimal places. Plots below 4 hectares require a single geolocation point plus area in hectares.
In practice, many suppliers have plots in the 2–6ha range where area estimates can straddle the threshold if measured loosely. We handle this by applying a 10% buffer zone: any plot where the reported area puts it within 10% of 4ha triggers polygon capture regardless, eliminating ambiguity at audit time. We convert field GPS traces to compliant GeoJSON polygons, validate topology (no self-intersections, minimum vertex count), and run automated QA checks before submission.
Review Your Geolocation Data03Identity-Preserved Supply Chain Traceability
EUDR requires traceability of commodities from each production plot through to EU market entry. The critical technical distinction: the regulation effectively requires identity-preserved traceability — not mass balance. Article 2 defines due diligence as verifiable evidence that a specific product came from a specific non-deforested plot. Mass-balance certified streams (common in palm oil and soy) do not satisfy this requirement on their own, even with RSPO or ISCC certification.
We build traceability systems that maintain batch-level linkage from plot-of-origin through every supply chain step: collector → processor → exporter. For commodities blended during processing — coffee wet mills, cocoa fermentation stations, palm oil mills — we implement lot segregation protocols and weight-based allocation to preserve the plot-to-batch link.
Integration with your ERP captures this chain-of-custody within existing procurement workflows. The data already exists in your systems; we make it compliance-ready.
Map Your Traceability Gaps
EUDR Compliance Architecture
How an ERP procurement event flows through the compliance pipeline to a TRACES NT Due Diligence Statement — and why each step is designed the way it is.
Architecture note: AWS Step Functions is the orchestration choice for a specific reason — the TRACES NT API submission involves 7+ sequential steps, each with distinct retry semantics. Transient network failures on the TRACES NT POST trigger exponential-backoff retry; validation failures (missing geolocation polygon, incomplete legality evidence) route to a human review queue and block shipment release in the ERP. Step Functions execution history also produces the audit evidence that shows regulators exactly when and how each compliance step completed.
04ERP Integration & AWS Step Functions Orchestration
Quick assessment:Pull last year's purchase orders for covered commodities destined for EU buyers. If that line exists in your ERP, the compliance workflow needs to originate there — automatically, not as a separate manual step.
We wire ERP procurement events into AWS EventBridge, which kicks off an AWS Step Functions state machine that orchestrates the full compliance workflow: fetch plot geolocation, verify deforestation, assess country risk tier, generate the Due Diligence Statement XML, submit to TRACES NT, store the DDS reference number, and release the shipment.
Step Functions is the right choice here because the TRACES NT API submission involves retry logic that must distinguish transient failures (network timeout — retry with exponential backoff) from validation errors (missing geolocation data — route to human review, block shipment). The visual state audit trail in Step Functions also produces compliance evidence that shows regulators exactly when and how each step completed. We have direct integration experience with Odoo; we adapt to your ERP environment across SAP, Microsoft Dynamics, and other enterprise platforms.
Discuss Your ERP Stack
05Offline-First Field Data Collection
Geolocation data collection in rural origin communities means working without reliable internet. We have direct production experience building offline-first progressive web applications (PWAs) for agricultural field data collection — including a deployment in Burundi for COSA, ICP, and Auxfin where smallholder coffee farmers in areas with no mobile coverage could capture GPS plot coordinates, farm attributes, and photographic evidence, with automatic sync to the cloud platform when connectivity was next available.
The technically hard part is not offline storage — it is sync conflict resolution when two field workers update the same plot with divergent GPS readings. Our approach uses server-authoritative last-write-wins with a coordinate-delta threshold: if two readings for the same plot differ by more than 10 metres, the conflict is flagged for supervisor review rather than silently overwritten. This is the kind of detail that prevents bad geolocation data from propagating into your compliance record.
Talk About Field Data Collection

06TRACES NT DDS Submission
TRACES NT (Trade Control and Expert System) is the EU's central information system for EUDR Due Diligence Statements. Every DDS must be filed and accepted by TRACES NT before the product is placed on the EU market — you cannot file retroactively. A successful submission returns a DDS reference number that must travel with the shipment and is cross-checked by customs in the member state of entry.
We implement automated DDS generation in the EU-specified XML schema: operator details, commodity CN code, country of production, plot geolocation, quantity and volume, deforestation-free attestation, legality attestation, and risk assessment summary. The DDS reference number returned by TRACES NT is stored against the batch in your ERP and signals shipment release. Management dashboards show DDS status across your supply chains; audit packages export the full evidence bundle for regulatory inspection — geolocation, satellite verification outputs, chain-of-custody records, and the submitted DDS XML.
EUDR Article 10 requires operators to retain all due diligence records — geolocation data, deforestation verification outputs, DDS XML, and chain-of-custody logs — for a minimum of 5 years. We design Redshift and S3 storage with appropriate lifecycle policies, legal-hold configurations, and access controls from the outset, so your compliance archive meets the retention requirement without a costly retrofit later.
Review Your Reporting ArchitectureEUDR Implementation Approach
Start with data collection, not the technology build. The compliance platform is straightforward to build. Getting plot-level geolocation data from hundreds of suppliers in low-connectivity areas — that is where December 2026 gets tight. The earlier you start, the better your position.
Supply Chain Assessment & Data Gap Analysis
Before building anything, we map your supply chain against EUDR scope: which commodities, which CN codes, which origin countries. We identify where geolocation data exists and where it needs to be collected, classify suppliers by country risk tier, and produce a prioritised data collection plan. This gap register drives everything that follows.
Geolocation Data Collection & Polygon QA
We establish geolocation data collection at the point of origin — via supplier self-service portal, offline-first PWA for field teams, or integration with existing farm management systems. Plots above 4 hectares receive polygon capture in GeoJSON WGS-84 EPSG:4326 format; smaller plots receive centroid plus area. Every submission passes automated topology QA before entering your compliance database.
Deforestation Verification Pipeline
Once geolocation data is in system, we build the satellite verification pipeline: Sentinel-2 imagery retrieval via the Copernicus API, NDVI-SWIR vegetation index computation for each plot from January 2021 forward, change detection against the regulatory cutoff date, and risk-scored output for each plot. Plots that exceed the change-detection threshold route to a human review queue with annotated satellite evidence rather than automatic rejection.
ERP Integration & Compliance Workflow
We integrate the compliance workflow with your ERP so purchase orders for covered commodities automatically trigger the Step Functions state machine: fetch geolocation, verify deforestation, assess risk tier, generate DDS XML, submit to TRACES NT. Shipment release is gated on a confirmed DDS reference number. No manual filing step, no way to accidentally skip it.
TRACES NT DDS Submission & Shipment Release
The AWS Step Functions workflow submits the completed DDS XML to TRACES NT via API. A successful submission returns a unique DDS reference number stored against the batch in your ERP. Transient API failures trigger exponential-backoff retry; validation failures (missing geolocation, incomplete legality evidence) route to a human review queue and block shipment. This prevents compliant shipments from being held and non-compliant ones from going through.
Audit Trail & Compliance Reporting
The Step Functions execution history, DDS XML records, satellite verification outputs, and chain-of-custody logs are archived in Redshift and surfaced through a compliance dashboard. Each shipment can produce a complete audit package: geolocation data, deforestation verification evidence, DDS reference number, and the submitted XML. This is the bundle competent authorities request at inspection.
Adapting to Change
Iterative compliance readiness — so you're prepared before the deadline, not scrambling at it.
Start With the Highest-Risk Gaps
We sequence readiness by impact: geolocation completeness, deforestation validation, legality checks, and DDS readiness, focusing first where regulatory downside is highest.
Start Your EUDR Compliance Build Now
The December 2026 deadline is closer than it looks once you factor in supplier geolocation collection, satellite verification build, TRACES NT integration, and test cycles. Talk to us about your commodity scope, ERP stack, and supplier geography — we will give you a realistic build estimate and tell you where your critical path actually sits.
Domains We Serve
Our software delivery and AI work spans regulated, data-intensive industries where technology drives measurable outcomes.
AgriTech & Sustainability
Offline-capable field data collection platforms and supply chain compliance tools deployed across East Africa, South America, and South Asia. PWAs with local data sync, SMS fallback, and voice interfaces. EUDR compliance workflows, traceability mapping, and certification body integration.
Telecom & Connected Systems
Connected device platforms with data ingestion pipelines for high-volume telemetry. Device management portals, real-time operational dashboards, and MQTT/CoAP integration for industrial and agricultural sensor networks.
Smart Energy
Energy monitoring dashboards, consumption analytics, and predictive maintenance systems. We integrate with smart meter APIs and building management systems to reduce waste and meet sustainability targets.
Governance & Compliance
Regulatory compliance platforms, governance assessment tools, and audit management systems. Survey platforms tracking sustainability indicators across global supply chains, with multi-language support and role-based access.
Technology Stack
Our EUDR compliance platforms use Python with PostGIS for geospatial processing, Sentinel-2 satellite imagery via the Copernicus API for deforestation verification, and AWS Step Functions to orchestrate the six-step compliance workflow — from geolocation fetch through TRACES NT Due Diligence Statement submission.
DynamoDB handles plot-level geolocation storage at the read throughput required for large supplier networks. Redshift powers compliance analytics and audit reporting. The specific stack is adapted to your existing ERP and infrastructure.
Engagement Models
We tailor delivery to your team structure and ownership preference. For full process detail, review the dedicated engagement model page.
Outsourcing
- Outcome-based delivery ownership
- Managed roadmap, QA, and releases
- Best for end-to-end product builds
Staff Augmentation
- Engineers integrated into your team
- You keep sprint and release control
- Best for scaling delivery capacity fast
Tech Consulting
- Architecture and platform strategy guidance
- Roadmap, risk, and cost optimisation
- Best for audits, modernisation, and decision support
Useful Reads
Frequently Asked Questions
Common questions about EUDR compliance requirements, enforcement timelines, TRACES NT submission, and how we help commodity importers and exporters build compliant systems. Australian exporters: see the AU-specific guide for LOW-RISK status, NLIS-aware design, and AU data residency.








