The good reason for overcoming EUDR IT issues:
it’s the economy, stupid!

Written by Clément Collignon, CEO at Sustaain

Sustaain, the Bordeaux-based AI company building systems for sustainable trade, today called for a pragmatic but firm approach to the EU Deforestation Regulation (EUDR).

Speaking at the webinar “EUDR: From Tech Uncertainty to Economic Opportunity” — initiated by MEP Pascal Canfin — Clément Collignon, CEO of Sustaain, argued that postponing implementation would do more harm than good — for both business and the planet.

“By trying to safeguard business as usual, we’re actually impairing business continuity,” Collignon warned.

Sustaain manages systems that process over 100 000 farm plots per day for major players such as Touton and Group Sopex. It leverages a proprietary database of 200 000 companies and 5 000 financial institutions with links to deforestation. From this vantage point, the company sees a clear picture: the EUDR is technically manageable — and economically desirable.

Feedback from traders: compliance is the new continuity

Over the past months, Sustaain has gathered extensive feedback from commodity traders. They are the operators  who handle the bulk of Europe’s soy, beef, cocoa, coffee, and palm-oil imports, and as such are the primary focus points of EUDR regulation. Looking at Trase.earth data, a handful of firms dominate Europe’s deforestation-linked imports:

• In the Brazilian sectors of Soy and Beef, critical for deforestation, 4 firms gather 90% and 50% of EU imports respectively.

• Globally, three companies handle half of all palm oil, four traders control half of cocoa and beef, and just twenty-five firms account for half of coffee imports. 

Traders are not just intermediaries — they are the risk-bearers of global supply chains and the operators legally placing products on the EU market. They sit at the junction between producers, customs authorities, and downstream brands, managing both physical shipments and data flows. Testing the EUDR IT system with these actors is therefore critical: their participation ensures that digital compliance tools perform under real-world, global-scale conditions — where one failed upload can mean millions in delayed trade.

These operators want to comply — not only for reputational reasons but because it makes economic sense. They have already built compliance systems, hired staff, and deployed traceability tools. Their main message to Brussels: don’t move the goalposts, let the system now be tested at scale by economic operators, not delayed on principle.

“Our concern is not compliance — it’s last-minute IT changes that threaten operations,” one major trader told Sustaain.

The system works — if you let it

The Commission’s own Roswall & De Carlo letter (23 Sept 2025) expressed concern that the EUDR IT system could slow down “to unacceptable levels.” Sustaain argues that the solution is engineering, not postponement.

Sustaain estimates the EUDR data load for traders to be maximum 100 TB per year — tiny by modern cloud-infrastructure standards. A dress-rehearsal exercise conducted by the EU Commission IT team is said to have processed around one million Due Diligence Statements, prompting concern about potential slowdowns. Yet the private sector has already implemented scalable ingestion, elastic traffic routing, and distributed submission architectures — tools proven to sustain high-volume compliance systems.

To make it work, Sustaain calls for a “fix, don’t freeze” strategy — combining regulatory certainty with stronger implementation support, more structured testing by economic operators themselves, and shared results across the industry.

Cancelling a regulation before enforcing it? A red-tape oxymoron

Postponement may sound prudent but economically, it’s a trap. Each month of uncertainty freezes investment, penalizes early movers, and adds risk premiums to trade and credit. The facts are unequivocal:

• A recent study found that full EUDR compliance would reduce Argentina’s GDP by just 0.14%, while cutting deforestation by 2.45 %. This shows costs are minimal compared with the benefits of clarity and enforcement. 

• Investment confidence has already weakened amid uncertainty: Ivory Coast is seeing a sharp decrease in sustainability investment after reaching 40 % traceability for cocoa exports. 

• The 2025 Forest 500 review shows many companies delaying ESG investment pending regulatory clarity — a textbook case of hesitation creating economic risk.

Delaying EUDR raises capital risk, fragments trade, and punishes firms that have already invested in compliance. The cost of clarity is limited; the cost of confusion compounds daily. The cost of delay exceeds the cost of doing. 

Even major food and agri-business groups — including Nestlé, Mars Wrigley, and other signatories to the Joint Industry Letter (2 Oct 2025) — have urged the EU to keep the December 2025 schedule and focus on execution, not delay, proposing legal solutions in case of platform unavailability.

“This is about economic leadership,” Collignon concluded. “EUDR isn’t a bureaucratic hurdle — it’s Europe’s chance to prove that sustainability and competitiveness can scale together.”

Six steps to make EUDR a success

In addition to proposing its expertise to address the technical concerns raised,
Sustaain proposes six immediate measures to strengthen EUDR delivery:

1. Lock in stability and clarity - Confirm the Dec 2025 timeline; avoid late revisions.

2. Fund economic impact research - Fund economic research work to model EUDR’s effects within the EU, in producer countries, and across global trade.

3. Work with sectoral organizations - Co-design practical playbooks for cocoa, coffee, soy, palm, beef, timber and rubber.

4. Create a cross-sector coordination body - Unite industry, NGOs, Member States, and the Commission to monitor and update guidelines.

5. Support exporters and smallholders - Make EUDR an engine for development, with financing and technical help in producing regions.

6. Continue dialogue and transparency - Publish performance data and guidance regularly to keep markets confident.