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What NVWA’s EUDR “dry-run” inspections just revealed — and what traceability teams must do next


On 21 August 2025, the Dutch food and product safety authority (NVWA) published the results of its spring “proefinspecties” (trial inspections) with companies preparing for the EU Deforestation Regulation (EUDR). The findings offer rare, practical insight into how authorities will evaluate EUDR readiness — and where many organisations are still falling short. 


Below we unpack what happened, why it matters for traceability, and the concrete steps to take before the Regulation starts applying to large operators and traders on 30 December 2025 (and to micro/small companies on 30 June 2026). 

What happened in the Netherlands

  • NVWA ran collaborative “dry-run” inspections with volunteer companies across several sectors that handle EUDR-covered products. The aim was to test due diligence systems and see what works in practice. 
  • Key insights from inspectors:
    • Due diligence is more than collecting data. Many firms gathered the right documents but didn’t actually assess risk or tie findings to mitigation actions — both are mandatory. 
    • Platforms help — they don’t replace due diligence. Software can structure data collection and screening, but legal responsibility remains with the operator to judge evidence and decide on mitigation. 
    • Certification ≠ compliance. Third-party schemes can be used as risk-mitigation evidence, but they cannot substitute an operator’s own due diligence decisions. 
    • Embed EUDR in day-to-day operations. Systems integrated with purchasing, sales, inventory, and internal traceability performed far better than bolt-on processes. 
    • Processing sites are a hotspot. Companies require input–output overviews at processing points to demonstrate that no mixing occurs with unknown origins and to minimize the risk of mixing to “negligible.” 
    • Link the physical product to the plot of origin. It’s not enough to know a farm is compliant; you must prove the product placed on the market is the same material from that location — i.e., robust first-mile traceability that survives every transformation. 

The regulatory bar you must clear.

  • Application dates. The EUDR applies from 30 Dec 2025 for large operators/traders; 30 Jun 2026 for micro and small companies. Each consignment must be covered by a Due Diligence Statement (DDS) submitted via the EU EUDR Information System. 
  • EUDR Information System. The EU system is a repository for DDS submissions; it does not generate farm geolocations for you. You’ll still need your own tools for mapping and evidence. 
  • Certification & mass-balance. Commission guidance reiterates: certifications can support risk assessment, but they don’t create a “green lane.” Critically, mixing compliant and unknown-origin material (mass-balance with unknowns) is not acceptable under EUDR. Traceability must reach back to the plot of land. 
  • National guidance (NL). NVWA’s implementation pages confirm: submit a DDS for every shipment in the EUDR Information System (inside TRACES), designate responsible staff, keep documentation for 5 years, and (for heavy users) consider an API integration to automate submissions. 

A practical readiness checklist (what to do now)

  1. Map suppliers to plots. Ensure you have plot polygons/points for every supplier that will ship to the EU from December 2025, and that you can bundle them by consignment to feed the DDS. 
  2. Stand up processing-site controls. Implement lot/batch IDs, input–output recon, and documented no-mixing controls; avoid any model that blends with unknown origin. 
  3. Operationalise risk assessment. Move from “file storage” to repeatable risk scoring and mitigation triggers (e.g., site audits, additional evidence, supplier improvement plans). Record decisions and outcomes. 
  4. Prepare for DDS at scale. Decide who signs DDS, define data owners, and — if you file many statements — plan an API connection to the EUDR Information System (TRACES). Test on the acceptance environment before going live. 
  5. Tune your certification strategy. Use certifications selectively to reduce specific risks (e.g., legality verification, HSE controls). Validate scheme scope vs. EUDR requirements; don’t rely on certifications alone. 
  6. Close the documentation loop. Adopt a 5-year retention policy, publish large-company annual summaries, and embed EUDR reviews in your yearly planning cycle. 

How Farmforce can help (first-mile traceability that stands up to inspections)

  • Origin: Farmer and plot registry with polygon/point capture, land-use evidence, production periods, and document vault — the building blocks for plot-level traceability.
  • Orbit: A chain-of-custody data pipeline designed to preserve identity and verify controlled mixing, with input–output reconciliation at processing points.
  • Insights: Dashboards and audit packs that stitch geospatial checks, risk scoring, mitigation actions, and DDS-ready consignment data into one evidentiary trail.

We also integrate with external risk tools and the EUDR Information System workflow (including data export aligned with DDS fields) so your operational due diligence flows cleanly into regulatory submission. (Note: the EU system stores DDS; it doesn’t map your farms — that’s still on you.)

Final word: think “evidence chain,” not “document pile”

NVWA’s dry-runs make one thing clear: success under EUDR is less about having a stack of PDFs and more about showing a controlled, repeatable process from plot to port — one that flags risk, documents action, and keeps the physical product provably linked to its origin. If your traceability can survive that journey, your DDS will, too. 

This article summarises public guidance from NVWA and the European Commission and is for information purposes only; it is not legal advice.

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