Navigating EUDR: compliance and beyond | Soy
Supporting businesses with regulatory compliance and advancing sustainability.
Why sustainability legislation matters
Sustainability legislation has expanded rapidly in recent years. Increasingly, addressing issues such as deforestation and human rights risks within supply chains is no longer a voluntary choice by responsible businesses but a legal obligation for all. New regulations have the potential to accelerate the transition to sustainable business practices and deliver positive impacts for people and planet at scale. But they also bring challenges.
If not carefully implemented, such legislation may increase administrative burdens without driving meaningful change on the ground. There is a risk that a strong focus on compliance may cause businesses to focus solely on their own sourcing footprint, rather than encouraging broader, more holistic industry-wide progress.
Credible voluntary sustainability standards (VSS) have been laying the groundwork for companies to implement responsible practices for years, offering tools, frameworks, and collaborative approaches that help businesses navigate this evolving regulatory landscape.
With decades of on-the-ground experience, credible VSS are uniquely positioned to address deforestation and land conversion. They provide the strongest available evidence of impact and effectiveness, making them strong partners for businesses aiming to meet new deforestation and conversion free (DCF) requirements while building more resilient and responsible supply chains.
Crucially, these systems go beyond compliance. They help businesses proactively tackle broader environmental and social issues, creating long-term value and preparing them for future regulations.
This series of case studies looks at how credible VSS are responding to one of the most important legislative developments: the EU Deforestation Regulation (EUDR), which aims to prevent products associated with deforestation from being sold on the EU market.
By leveraging proven standards, facilitating reliable data exchange, and managing risk across complex supply chains, credible VSS are critical in helping businesses meet DCF requirements. These case studies show how credible VSS drive not only compliance but also meaningful transformation across sectors and supply chains.
The soy supply chain
Soy is one of the most traded and versatile crops in the world, used in animal feed, vegetable oils, biofuels and a wide range of foods, cosmetics and industrial products. Around 80% of global soy is processed into meal for livestock, meaning much of it is consumed indirectly through meat, dairy and eggs. Production is concentrated in Brazil, Argentina and the United States, with China and Europe as major importers. The supply chain is complex and global, with “embedded soy” hidden in processed goods and animal products, making it difficult to trace origins.
Rising demand has driven large-scale conversion of forests, savannahs and grasslands in regions such as the Amazon, the Cerrado and the Gran Chaco, contributing to greenhouse gas emissions, biodiversity loss and the displacement of local communities. As scrutiny grows, businesses face mounting pressure to source soy responsibly. In Europe, more than half of imports are now covered by sustainability certification, and EUDR requirements for soy to be deforestation-free, legal and traceable are driving further efforts to strengthen accountability across supply chains.
Various sustainability standards, certification systems and collaborative initiatives aim to improve environmental and social practices in soy production while reducing deforestation and ecosystem conversion. Two prominent international voluntary sustainability standards active in the sector are the Round Table on Responsible Soy (RTRS) and ProTerra.
RTRS, founded in 2006, is the largest soy certification system globally, with over 30,000 certified growers certified in 2024, and over 400 certified sites across 16 countries. It certifies both GMO and non-GMO soy. Europe is the largest market for RTRScertified soy, accounting for the majority of certified imports.
The ProTerra Standard v5.0 is specifically focused on non- GMO soy, with a strong uptake in European markets where GMO-free supply is in high demand. Like RTRS it provides internationally recognised certification for deforestation-free soy production and applies to both large-scale producers and smallholder groups.
Other regional and national initiatives complement these international standards. Donau Soja certifies sustainable, traceable European non-GM soy. VISEC is a collective effort to enable traceable, deforestation-free soy from Argentina. The Soy Moratorium in Brazil is a public-private agreement that prevents the purchase of soy cultivated on recently deforested Amazon land, though its future has recently come under legal and regulatory challenge. FEFAC, the European Feed Manufacturers’ Federation, supports industry-wide coordination on responsible sourcing, certification and regulatory compliance. The UK Soy Manifesto is an industry effort to ensure all physical imports of soy to the UK are deforestation- and conversion-free by the end of 2025. The Soy Transparency Coalition is a pre-competitive coalition that aims to help supply chain companies and investors overcome transparency challenges in the soy sector to deliver a sustainable production system. Collaborative programmes led by organisations such as Solidaridad provide training, technical assistance and capacity-building for smallholder farmers.
Understanding the EUDR: challenges and requirements for soy
Traceability is a core requirement under the EUDR, but soy presents particular challenges due to the structure of its supply chain. Few retailers buy soy directly; instead, it is usually traded through various intermediaries. Distances between farms and storage facilities can be long, and storage is often outside the control of major traders or cooperatives. Competition between different actors in the supply chain can also discourage information-sharing, particularly in key producing countries such as Brazil and Argentina. Traceability is further complicated by the widespread use of soy in processed products and animal feed, and by its storability, which allows traders to hold stock for extended periods depending on market conditions, in contrast to more perishable commodities. Finished products and soy embedded in meat and dairy are not currently within the EUDR scope. Tracing soy back to its farm of origin requires robust systems and coordination across multiple stakeholders. Achieving full traceability will require agreement among supply chain actors on standards, best practices and data sharing, alongside investment in monitoring and reporting systems.
Beyond deforestation, soy is a key driver of conversion of other important habitats like savannahs and grasslands. These are not currently included in the EUDR. A narrow focus on compliance risks displacing production into nonforest ecosystems.
The EUDR’s legal production requirement means that, in addition to being deforestation-free, soy must be produced in compliance with the laws of the country of origin. Importers, traders, processors and retailers must carry out due diligence to ensure soy is legally produced. This involves tracking, monitoring and maintaining evidence of land rights, permits and environmental compliance, among others.
Navigating this requirement can be complex due to differences in land tenure, environmental regulations and labour laws across producing countries. In some regions, land is managed collectively or through cooperatives, which can complicate documentation and verification. Variability in enforcement, record-keeping and national legal frameworks can create obstacles for companies seeking to demonstrate compliance under the EUDR, so approaches may need to be adapted for different regions.
The EUDR requires companies to collect and maintain vast amounts of data to demonstrate both deforestation-free and legal production. This means compiling geolocation data, land-use records, permits and environmental compliance information across highly fragmented supply chains. Data systems must not only capture information at farm level but be able to track this as it moves through the supply chain. In many producing countries, differences in data availability, quality and accessibility create additional challenges. As a result, companies need harmonised approaches to data collection and management that ensure accuracy and consistency across the supply chain, while avoiding placing disproportionate burdens on smaller producers.
How credible standards can support businesses with regulatory compliance
Voluntary standards like RTRS and ProTerra provide credible frameworks that help companies demonstrate compliance with deforestation-free and legal production requirements under regulations like the EUDR. By embedding robust verification and documentation systems, they reduce compliance risks, strengthen supply chain transparency and support broader sustainability objectives.
RTRS and ProTerra are already adapting their frameworks to align with the EUDR and other regulatory obligations. Voluntary standards and certification are not, however, a substitute for companies’ own responsibility to demonstrate compliance with the EUDR.
The EUDR uses the UN Food and Agricultural Organization (FAO) definition of forest, which applies to any area of more than 0.5 hectares with vegetation higher than five metres and more than 10% foliage cover. Its cut-off date, after which no deforestation is permitted, is 31 December 2020.
Both RTRS and ProTerra have broader definitions and earlier cut-off dates. RTRS prohibits conversion of native forests and high conservation value areas, based on the Accountability Framework Initiative definition of deforestation which encompasses the EUDR scope. Its cut-off dates are May 2009 for natural forests and some other natural ecosystems, and 3 June 2016 for all natural ecosystems. ProTerra Standard Version 5.0 has a stricter cut-off date of December 2008 and protects a broader range of ecosystems beyond forests, including wetlands, savannahs, floodplains and steep slopes.
While certification is not a guarantee that soy imports meet the EUDR’s legal production requirements, voluntary sustainability standards can support companies in their legality and due diligence obligations.
RTRS certification requires compliance with applicable laws at farm level: certification audits include checks on land tenure, labour practices and environmental management, backed by third-party verification. The standard has been developed through extensive multistakeholder engagement, giving it credibility across supply chain actors, which supports due diligence and risk assessments. RTRS publicly shares certified producers’ audit reports to promote transparency.
ProTerra similarly offers supply chain certification and supports farm-level compliance through verification audits. ProTerra’s MRV standard explicitly supports due diligence and risk mitigation, requiring certified organisations to carry out risk assessments, implement corrective actions and undergo independent thirdparty audits. ProTerra audit reports and certificates can serve as documentation for due diligence statements under the EUDR, helping businesses demonstrate that their soy has been legally produced.
The EUDR requires traceability back to the precise location where commodities were produced. As outlined above, this is particularly challenging in the case of soy, but both RTRS and ProTerra operate chain of custody systems that enable this level of traceability.
In its latest chain of custody standard revision, RTRS has introduced an optional model specifically designed to align with EUDR requirements on traceability, due diligence and documentation. It can be applied to either fully segregated RTRS certified soy or EUDR-RTRS-mix – a mix of certified and non-certified soy also known as controlled mass balance in ISEAL's Revised Chain of Custody Models and Definitions Guidance v2 (2025) – and ensures EUDR-compliant soy is kept separate from soy that doesn’t meet EUDR requirements throughout the supply chain. The module is third-party audited and was developed through multiple rounds of stakeholder consultation. The latest standard also includes a new ‘lean’ chain of custody model designed to improve transparency for supply chain actors acquiring embedded soy.
In its latest revision, ProTerra introduced the concept of verified mass balance to ensure that non-certified volumes that come from deforested areas do not enter the certified flow. ProTerra uses a segregated chain of custody system, ensuring physical traceability of certified soy through every step of the supply chain. Certified companies are also required to maintain clear sourcing, processing and trading records – in line with the EUDR’s emphasis on geolocation-based traceability and transparent documentation.
Companies can also be audited against the ProTerra Monitoring and Verification (MRV) Standard, a systematic approach to assessing and verifying an organisation’s management system and due diligence practices. A benchmarking exercise in January 2025 found that the ProTerra MRV Standard fully aligned to all relevant EUDR articles.
Supporting smallholder inclusion
Meeting the requirements of the EUDR and other legislation can be particularly challenging in the case of smallholders, who may lack the relevant documentation. As a result, companies may instead focus on larger suppliers to reduce the cost of due diligence and risk mitigation. This could lead to a range of negative consequences for smallholders, including reduced market access, loss of livelihoods, and weakened incentives to adopt more sustainable production practices. Ensuring smallholder farmers and other vulnerable groups are included in sustainable supply chains is a core focus of credible standards.
RTRS offers a group certification model, which provides a simplified, cost-effective way for small-scale producers to meet sustainability criteria. Certification creates a pathway for smallholders to access markets demanding verified deforestation-free soy, and ensures they are not sidelined by the requirements of the EUDR. RTRS also collaborates with local partners to provide training, capacity-building and technical assistance on issues such as legal compliance, good agricultural practices and labour rights, helping smallholders build long-term resilience and competitiveness.
ProTerra also offers group and multi-site certification, which allows smallholder groups and cooperatives to share certification costs, lowering barriers to entry for producers with limited resources. Their ProTerra Smallholder Interpretation further supports inclusion through a stepwise approach in which producers meet initial requirements at entry level, additional ones by the third year, and all requirements by the fifth year, with full compliance expected after the sixth year. This phased process allows smallholders to align with the ProTerra Standard at a pace suited to their local realities. Meeting the ProTerra standard helps smallholders align with the EUDR and other upcoming sustainability regulations, future-proofing their practices. Training, technical partnerships and practical support enable smallholders to meet the standard and carry out any necessary corrective actions.
- Webinar on the new version of the RTRS Chain of Custody
- RTRS Chain of Custody Standard V3.0
- RTRS Standard for Responsible Soy Production V4.0
- The ProTerra Standard Interpretation for Smallholders
- The ProTerra Standard
- ProTerra Standard V5 and the European Regulation on Deforestation-free Commodities (EUDR)
- ProTerra Monitoring and Verification (MRV) Standard and the European Regulation on Deforestation-free Commodities (EUDR)
- ProTerra MRV Standard
Supported by
