The EU Deforestation Regulation (EUDR) is changing how companies sourcing certain commodities and derived products from global supply chains must demonstrate compliance.For suppliers outside the EU, including manufacturers in China, EUDR compliance can involve much more than providing a standard certificate of origin or a supplier declaration. EU customers may require detailed information about the origin of raw materials, production locations, geolocation data, legality of production and evidence that products are deforestation-free.For Chinese manufacturers supplying European customers, understanding and preparing the required supply chain information is becoming an essential part of doing business with the EU.

What is EUDR?

The EU Deforestation Regulation is designed to ensure that certain products placed on or exported from the EU market are not associated with deforestation or forest degradation.The regulation covers commodities including:

• Cattle
• Cocoa
• Coffee
• Palm oil
• Rubber
• Soy
• Wood

It also applies to certain products derived from these commodities that fall within the regulation's scope.For industrial supply chains, natural rubber and rubber-containing components can be particularly relevant, depending on the product and applicable tariff classification. Examples may include certain seals, gaskets, O-rings, belts, rubber components and other products.Importantly, not every product containing rubber or another listed commodity is automatically within EUDR scope. The specific product, composition and applicable CN/HS classification must be assessed.

What Does EUDR Mean for Chinese Suppliers?

One of the biggest challenges is traceability beyond the immediate supplier.An EU customer may need information that goes beyond the Chinese factory producing the finished component.For example:EU customer → Chinese manufacturer → rubber compound supplier → natural rubber supplier → production plotThis means that a Chinese manufacturer may need to work with its own upstream suppliers to collect information about the original commodity.Depending on the product and supply chain, required information may include:

1. Product information

Suppliers may need to provide:

• Product description
• Trade name and product type
• Relevant commodity
• Raw material or species information where applicable

2. Quantity

The relevant quantity may need to be documented by:

• Net mass in kilograms
• Volume
• Number of units

3. Country and region of production

The supplier may need to identify the country of production and relevant region of the commodity.

4. Geolocation information

This is one of the most challenging aspects of EUDR compliance.For relevant commodities, suppliers may need to provide the geolocation of the production plots and the applicable production date or date range.For example, simply stating:

"Natural rubber – Thailand"

may not be sufficient.The supply chain may need to identify the specific production plots and corresponding geographical coordinates.

5. Evidence that the product is deforestation-free

Suppliers need to be able to provide verifiable information demonstrating that the relevant products are deforestation-free.

6. Evidence of legal production

Information may also be required to demonstrate compliance with the laws of the country of production, including relevant land-use rights and other applicable legal requirements.These requirements can create a significant documentation and coordination burden for manufacturers whose upstream supply chain has not previously been required to provide this level of traceability.

How Can Empower Support EUDR Supplier Compliance?

Empower helps EU buyers and their Chinese suppliers bridge the gap between EUDR requirements and the realities of China's multi-tier manufacturing supply chain.We can support the process from supplier identification and information collection through to documentation review and compliance data preparation.

1. EUDR Scope Assessment

We help determine whether the products and materials in a supply chain may fall within the relevant EUDR scope.This can include reviewing:

• Product specifications
• Raw material composition
• Product classifications
• Relevant suppliers and manufacturing locations

Where necessary, specialist regulatory advice can be sought for formal legal interpretation.

2. Supplier EUDR Questionnaire Management

We can prepare and coordinate EUDR questionnaires for Chinese manufacturers and their upstream suppliers.Instead of an EU customer having to communicate separately with multiple Chinese factories, Empower can act as a local coordination point to:

• Distribute questionnaires
• Explain the information requirements in Chinese
• Follow up with suppliers
• Identify missing information
• Consolidate responses

3. Supply Chain Traceability

For products requiring deeper traceability, Empower can help map the supply chain beyond the immediate manufacturer.We can work with suppliers to identify:Finished product → component supplier → raw material supplier → commodity originThis is particularly valuable where the EU customer needs visibility into Tier 2 or Tier 3 suppliers.

4. Geolocation & Origin Data Collection

Where geolocation information is required, Empower can coordinate with suppliers and upstream commodity producers to collect the relevant production location data and supporting documentation.We can help suppliers organise information such as:

• Production country
• Region
• Production plot
• Geolocation coordinates
• Production dates
• Relevant supplier information

5. Supporting Document Collection & Review

We can help collect and organise supporting evidence relating to:

• Raw material origin
• Deforestation-free status
• Local legal compliance
• Land-use rights where applicable
• Supplier due diligence systems
• Relevant certificates and declarations

Empower can also conduct a document completeness and consistency review before the information is submitted to the EU customer.

6. Supplier Follow-up and Corrective Action

EUDR compliance is rarely achieved through one questionnaire.Suppliers may submit incomplete information, inconsistent origin data or documents that do not adequately support the required claims.Empower can follow up with suppliers, identify gaps and coordinate corrective actions and additional documentation.

7. EUDR Data Package Preparation

Once the required information has been collected, Empower can organise it into a structured EUDR supplier compliance data package for the EU customer.This can help the customer conduct its own due diligence and prepare the relevant Due Diligence Statement (DDS) where applicable.Empower supports the preparation and verification of supplier information; the legal responsibility for submitting a DDS remains with the relevant operator or other party responsible under EUDR.

Why Use Empower?

EUDR compliance can be particularly challenging when the supply chain is located in China because EU buyers may face:

• Language barriers
• Multiple tiers of suppliers
• Limited visibility beyond Tier 1
• Incomplete documentation
• Difficulty obtaining geolocation data
• Different interpretations of compliance requirements
• Slow supplier response times

Empower provides a local China-based interface between European buyers and Chinese supply chains.Our existing capabilities in procurement, supplier management, factory coordination, quality control and China trade compliance enable us to work directly with Chinese suppliers and help turn regulatory requirements into practical supply chain actions.

From EU requirements to China supply chain execution

EU Customer / EUDR Requirements

↓

Empower – Requirement Analysis & Supplier Coordination

↓

Chinese Manufacturer

↓

Upstream Suppliers & Raw Material Sources

↓

Origin / Geolocation / Legality / Deforestation-Free Evidence

↓

Verified EUDR Supplier Data Package

↓

EU Customer's Due Diligence Process

Make Your China Supply Chain EUDR-Ready

EUDR compliance is not simply a matter of obtaining a certificate. For many products, it requires traceability, evidence, supplier cooperation and reliable data management across multiple levels of the supply chain.If your European business sources EUDR-relevant products or components from China, Empower can help you engage Chinese suppliers, collect the required information, identify documentation gaps and build a more transparent and EUDR-ready supply chain.Empower — Your China Supply Chain Partner for EUDR Supplier Compliance.

FAQ

Question: Does a manufacturer need to trace its raw materials beyond its direct supplier?

Answer: In some cases, yes. EUDR compliance may require supply chain information beyond the Tier 1 supplier. For example:EU customer → Chinese manufacturer → raw material supplier → commodity producer → production plotThe required level of traceability depends on the product and the applicable EUDR requirements.

Question: Can Empower communicate directly with our Chinese suppliers?

Answer: Yes.Empower can act as your local China-side coordinator, communicating with manufacturers and upstream suppliers in Chinese, explaining the required information, following up on outstanding documents and helping resolve information gaps.This can significantly reduce the communication burden for European companies managing multiple Chinese suppliers.