Smallholders and the European Union Deforestation Regulation

The EUDR is reshaping market access for agricultural commodities by introducing mandatory requirements for deforestation-free production, traceability, and legality. While the regulation applies primarily to companies placing products on the EU market, its requirements have significant implications for the smallholder farmers who supply these value chains. 

This report examines the challenges and opportunities that the EUDR presents for smallholders and explores what is needed to support their continued participation in EUDR-compliant supply chains. Drawing on a survey of 333 smallholder farmers and farmer organizations across 16 countries in Africa, Asia, and Latin America, the report assesses farmers’ awareness of the EUDR, their preparedness to meet compliance expectations, the barriers they face, and the support mechanisms they consider most important. 

Key Findings 

The research finds that awareness of the EUDR is relatively high among the surveyed producers, but readiness to comply remains uneven. While most respondents had heard of the regulation and many had received some form of guidance or training, significant structural barriers continue to constrain their ability to demonstrate compliance. These include challenges related to land tenure and legality, compliance costs, traceability and geolocation, technical and digital capacity, and access to producer organizations and support services. 

The research also highlights a significant risk of market exclusion and leakage. About three-quarters of respondents believed that stricter compliance requirements could push producers toward less regulated markets if they cannot access affordable and practical pathways to compliance. This could undermine both the environmental objectives of the EUDR and smallholder livelihoods. 

At the same time, participation in voluntary sustainability standards and sustainability initiatives can provide an important foundation for EUDR compliance. Producers involved in these initiatives generally reported stronger documentation, traceability systems, training, and access to compliance support. However, certification alone does not guarantee EUDR compliance, highlighting the need for greater alignment between existing sustainability systems and regulatory requirements. 

Pathways to Compliance 

The report identifies three complementary pathways to strengthen smallholder inclusion in EUDR-compliant supply chains: 

1. Strengthen producer support through VSSOs and sustainability initiatives. VSSOs can build on existing certification, traceability, and producer organization systems to support EUDR readiness. This includes aligning requirements with the EUDR, reducing duplication in data collection, providing training and technical assistance, and facilitating access to tools for geolocation, traceability, record-keeping, and risk assessment.
2. Build an enabling policy environment. Governments have an important role in addressing structural barriers that individual farmers cannot resolve alone. Priorities include strengthening land administration and farmer support services, investing in shared traceability and data systems, improving digital infrastructure, and providing targeted financial and technical assistance.
3. Strengthen responsible supply chains through private sector action. Buyers and downstream operators can support suppliers as part of their due diligence and risk mitigation. Supplier support can help address gaps in traceability, documentation, technical capacity, and compliance systems while reducing the risk that smallholders are excluded from regulated markets. 

Ultimately, the report argues that smallholder inclusion should be central to EUDR implementation. Achieving the regulation’s objectives will require more than compliance requirements alone: it will require coordinated investment and support that enables smallholders to meet those requirements while remaining viable participants in sustainable global supply chains.