System Due Diligence
Cooperation with suppliers
Article 9 of Regulation (EU) 2023/1115 (EUDR) specifies the information that traders must collect in order to comply with due diligence requirements. Some of this information is also included in Annex II to the Regulation, which describes the elements of the declaration to be submitted in the electronic system provided by the European Commission (EU TRACES). The submission of such a declaration results in the assignment of EUDR reference numbers, which can be used further down the supply chain as proof of due diligence.
This means that when importing products covered by the EUDR Regulation into the EU market, the importer must exercise due diligence and submit a due diligence declaration in the EUDR information system (EU TRACES). In such cases, the importer will have to collect the information on the products listed in Article 9 of the EUDR. If the imported products contain raw materials that have already been placed on the EU market and are therefore already subject to a previous due diligence declaration, the importer should be able to refer to that due diligence declaration using the reference number.
EUDR Process flow at Rawlplug is illustrated below:
To facilitate the process of collecting the required data, we have developed our own EUDR data collection form, which we provide to our suppliers. The form covers all the key information required by the regulation and allows us to carry out a reliable compliance assessment and prepare the relevant due diligence declarations in the EU TRACES system. Based on the data collected, we carry out a full due diligence process, minimising the risks associated with the origin of raw materials.
SYSTEM DUE DILIGENCE
Below is a summary of our EUDR Due Diligence System, which allows us to ensure that the products we purchase are deforestation-free and have been produced in accordance with the laws of their country of origin.
- Our approach to compliance
We have implemented a transparent system for verifying suppliers and monitoring purchases, which allows us to confirm compliance with EUDR requirements. It includes both the process of collecting and analysing data on the origin of materials, as well as risk assessment procedures and risk mitigation mechanisms.
- Source and legality of origin
Each supplier is required to provide documents confirming the legality of raw material sourcing, compliance with the regulations of the country of origin, and no connection with deforestation after 31 December 2020. This information is archived and may be subject to inspection by the relevant authorities.
- Standards and certifications
We primarily work with partners who have certificates and quality systems confirming responsible raw material management. In the case of wood and paper, we prefer suppliers with FSC or PEFC certificates, and for leather products, we require transparent information about the origin and processing methods.
- Traceability in the supply chain
We ensure that raw materials can be traced from their source to the finished product that reaches us. We verify data such as wood species, country and region of origin, as well as compliance with applicable laws and environmental standards.
- Declarations
We prepare due diligence statements for each category of materials under EUDR and submit them via the EU TRACES system. These are supplemented by regular reports and summaries documenting our activities in the area of responsible purchasing.
- Cooperation with partners
We treat due diligence not only as a regulatory obligation, but also as part of our partnership. We support our suppliers in meeting EUDR requirements, share our knowledge and expect open communication about risks and challenges.
- Our environmental and social commitments
The due diligence system also includes an analysis of potential risks to the environment and local communities. We focus on solutions that support sustainable development, reduce emissions and promote respect for human rights throughout the supply chain.