1. Weak Supply Chain Traceability System, Prominent Difficulties in Full-Chain Traceability
Supply chain traceability is a core requirement of EUDR compliance, which requires achieving "plot-level" precise traceability—i.e., providing the exact latitude and longitude (to six decimal places) of the production plots of product raw materials and verifying the consistency between the plots and satellite images. However, the current status of Chinese enterprises' supply chains is difficult to meet this standard.
On the one hand, the supply chains of Chinese export enterprises are mostly characterized by "multi-level and cross-regional" features. Especially for regulated categories such as wood, rubber, and soybeans, raw materials often come from high-risk regions such as Southeast Asia and Central Africa, with a large number of small farmers and small plantations upstream. These entities lack systematic data recording awareness and cannot provide key information such as plot coordinates, planting/logging time, and ownership certificates, leaving downstream enterprises unable to form a complete traceability chain. On the other hand, some enterprises have "mixed raw materials" in their supply chains. After mixing raw materials from different sources for processing, it is impossible to distinguish the raw material traceability information of a single batch of products, which is essentially inconsistent with EUDR's requirement of "batch corresponding to plot". In addition, Chinese enterprises have long relied on a compliance model of "document completeness", which is disconnected from EUDR's verification logic of "geographical fact consistency". Traditional documents such as invoices and shipping orders can no longer meet compliance requirements, making the upgrading and transformation of the traceability system an urgent but arduous task.
2. Insufficient Technical Support, Intergenerational Gap in Digital Compliance Capabilities
The implementation of EUDR relies heavily on digital technologies, such as GIS (Geographic Information System), satellite remote sensing monitoring, and blockchain traceability. However, the technical reserves of most Chinese enterprises (especially small and medium-sized enterprises, SMEs) are difficult to match this demand, forming an obvious "intergenerational technical gap".
According to relevant surveys, 70% of midstream processing enterprises are not equipped with GIS systems and cannot process and verify plot coordinate data; existing ERP systems are mostly used for production management and cannot automatically match "product batches" with "plot coordinates", requiring manual data entry with an error rate exceeding 30%. At the same time, enterprises generally lack capabilities such as satellite image comparison and real-time data collection, making it difficult to verify the authenticity of plot information provided by suppliers and unable to cope with EUDR's "suspicion + verification" audit logic—unlike the previous EUTR model of "trust + random inspection", EUDR defaults to confirming compliance through satellite or on-site inspections, with documents only serving as auxiliary evidence. This makes it difficult for enterprises without technical support to complete compliance verification. In addition, the investment cost of digital tools is relatively high; for example, the annual fee for a blockchain traceability platform can reach 80,000 to 200,000 yuan, and remote sensing data services also require certain expenditures, making the threshold for technical upgrading too high for capital-constrained SMEs.
3. Sharp Rise in Compliance Costs, SMEs Under Particular Pressure
EUDR's compliance requirements have directly pushed up enterprises' operating costs, with complex cost components covering digital construction, document certification, supply chain optimization, and other aspects, becoming an important obstacle for Chinese enterprises to implement EUDR. Among them, SMEs are under particularly significant pressure.
In terms of cost composition, one-time investments include traceability system construction, ERP upgrading, and employee training, among which system construction costs account for 40%-55% of the total cost; annual recurring costs include third-party verification, sorting of due diligence documents, relevant certifications such as FSC, and supplier training, with certification and audit fees alone reaching 150,000 to 500,000 yuan. In addition, supply chain optimization will also bring additional costs—for example, replacing non-compliant suppliers may lead to a 10%-30% increase in procurement unit prices, and the renovation of raw material isolation warehouses also requires investment. For large enterprises, these costs can be gradually absorbed, but SMEs have limited capital strength and most are operating on thin margins, making it difficult to bear high compliance investments. Although the EU proposed a simplification proposal in 2025, postponing the compliance deadline for micro and small enterprises to June 30, 2027, the problem of excessively high short-term compliance costs cannot be fundamentally solved. Some SMEs even face a dilemma of "compliance leading to losses, non-compliance leading to withdrawal".
4. Insufficient Cognition and Professional Capabilities, Lag in Compliance System Construction
Currently, Chinese enterprises still have deviations in their understanding of EUDR and insufficient professional compliance capabilities, leading to lagging compliance system construction and difficulty in adapting to regulatory requirements.
On the one hand, some enterprises have insufficient understanding of the "trade attribute" of EUDR, regarding it only as an ordinary environmental protection regulation and failing to recognize its core role as a "market access threshold". They ignore the urgency of compliance work and only respond passively when their products are blocked from export. On the other hand, enterprises generally lack professional compliance teams; most employees are not familiar with EUDR's due diligence processes and risk classification standards, making it difficult to interpret land laws of different producing countries and accurately complete tasks such as plot coordinate collection, risk assessment, and submission of compliance declarations. In addition, the traditional process of "document compliance—annual report—external audit" long formed by enterprises is inconsistent with EUDR's requirements of "real-time data collection—dynamic coordinate verification—system traceability". Solidified organizational inertia leads to slow transformation of the compliance system, making it difficult to quickly complete adaptation even with a grace period.
5. Insufficient External Coordination, Imperfect Compliance Support System
The effective implementation of EUDR requires the collaborative cooperation of enterprises, suppliers, industry associations, and regulatory authorities. However, China's current compliance support system is still imperfect, making external coordination difficult.From the supplier perspective, upstream small farmers and small suppliers lack compliance awareness and capabilities, are unwilling to invest costs to improve traceability records, and some even refuse to provide plot information, leading to obstacles in downstream enterprises' supply chain compliance. From the industry perspective, there is a lack of unified compliance standards and shared databases, making it difficult for enterprises to achieve resource sharing and cost sharing, further increasing the difficulty and cost for SMEs to build compliance systems independently. From the policy and service perspective, EUDR compliance guidance and training services for Chinese enterprises are still insufficient; the number of third-party verification institutions is limited, and their service prices are relatively high,
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