ISEAL commissioned SCS to examine how 'declaration in excess' is understood and used by supply chain actors to comply with the EU Deforestation Regulation (EUDR). Interviews with stakeholders in palm oil, coffee and rubber revealed varying levels of awareness, implementation strategies and potential hurdles. The report highlights different interpretations and implementations of declaration in excess, assessing both potential benefits and challenges from a regulatory and business perspective.

A common misconception in the discussion around EUDR compliance is the idea that every single grain of coffee or nib of cocoa must be tracked to its exact origin. Instead, the concept of declaration in excess allows operators to provide geolocation data for a larger number of plots than those directly linked to a specific shipment, if all declared sources meet EUDR compliance requirements.  

Overall awareness of declaration in excess remains low among the interviewed supply chain actors. While many recognise the practice once explained, there is reluctance to fully embrace it. This hesitation may be justified, as operators assume full responsibility for all declared plots, meaning that non-compliance in any one declared source could compromise the entire shipment. Companies must therefore weigh the operational benefits gained through declaration in excess against the risk exposure of a single-source compliance failure.

Download the full report below or read our blog here: Deforestation-free supply chains: The role of declaration in excess.