Europe Warehousing to be transformed by EUDR

The EUDR is a new EU law aimed at reducing global deforestation and limiting the EU’s contribution to greenhouse gas emissions and biodiversity loss. It imposes strict requirements on companies trading goods whose cultivation or production may contribute to deforestation. These include timber, coffee, soy, cocoa, rubber, palm oil, and cattle—as well as all products derived from them.

Medium-sized and large enterprises must demonstrate compliance starting December 30th, 2026, while small companies have an additional six months—until June 30th, 2027. Compliance means proving that products do not come from areas deforested after December 31st, 2020, and that they were produced in accordance with the laws, environmental standards, and human-rights regulations of their country of origin.

In the long term, the EUDR is likely to accelerate the growing importance of ESG practices in logistics. Products with complete environmental documentation will be prioritised by distributors and contractors, and operators with transparent processes will enjoy greater market trust. The regulation is expected to raise standards across the warehouse industry; it will apply to a broad range of Polish companies—from large importers and retail chains to smaller manufacturers and distributors. In practice, many companies involved in supply chains for food, wood, and rubber products will inevitably encounter EUDR requirements. Monika Woźniak, Senior Director, Industrial and Warehouse Agency, JLL

How Will Warehouse Processes Change?

Compliance checks will have to be built into warehouse processes before goods are released. Each batch will require full documentation, including GPS coordinates of the raw material’s origin, plantation or farm boundaries, manufacturer details, and confirmation that the land has not been deforested since December 31st, 2020.

A key role is played by the first operator (FOO)—the entity that first places a product on the EU market. The FOO submits a complete Due Diligence Statement (DDS). Subsequent supply chain actors, including logistics operators and warehouse companies, rely on the reference number of this statement. Their responsibility is to correctly store, use, and transfer the data—not to prepare a new DDS for each batch.

Penalties for non-compliance are severe. They may include detention of goods in ports or warehouses, confiscation of products, financial fines of at least 4 pct of the company’s annual EU turnover, or even a ban on operating within the EU. Small companies can submit a simplified, largely one-time declaration, which reduces the administrative burden but does not exempt them from ensuring supply chain transparency.

Meeting EUDR requirements may lengthen logistics operations and require additional staff. Every batch of regulated goods must be verified, assigned a unique identifier, and entered into the system with full traceability. Documentation must be retained for at least five years. In practice, no goods may leave a warehouse without confirmation that they have a valid DDS and full origin data.

The Impact of EUDR on the Logistics Industry

The EUDR transforms logistics operators from “neutral intermediaries” into guardians of supply chain compliance. Physical goods flows must now be synchronised with data flows—DDS numbers, raw material origin details, and supplier histories. This will require integrating warehouse systems with traceability solutions and strengthening cooperation with clients and data providers.

The regulation may accelerate the professionalisation of logistics services. Operators that previously focused mainly on space and transport will increasingly expand into advisory functions—documentation support, geographic risk monitoring, and continuous compliance reporting for retail and FMCG clients.

EUDR also increases operational risk. Incomplete documentation may result in goods being held at borders or in warehouses, affecting delivery times and necessitating updates to SLAs. Logistics operators will need to invest in IT systems, data-quality teams, and process adaptation—all of which raise fixed costs.

The regulation may also drive supply chain restructuring. As companies limit purchases from high-risk deforestation regions, import routes and logistics hubs may shift. For Poland—a major gateway for non-EU goods—this could mean growth in specialised warehousing for regulated products and higher demand for operators capable of managing regulatory risk. Early adopters that build EUDR compliance into their daily operations will be best positioned to benefit. Transparent processes, digital documentation, and ESG reporting capabilities will become crucial differentiators, even if they increase service costs. For many logistics operators, the EUDR may be the catalyst for upgrading their services and positioning themselves as trusted regulatory partners for global brands.

A Step Toward Full Supply Transparency

The new regulation demands end-to-end visibility across the supply chain. Companies must verify every supplier of EUDR-regulated goods—from plantation to warehouse.

Some suppliers may lack the necessary documentation or tracking systems. In such cases, companies will need to support them in data preparation or seek new partners who are already EUDR-ready.

Poland imports roughly USD 2.9 bln in cocoa products, over 1.5 mln tons of soybeans, and timber and rubber worth hundreds of millions of euros—mainly from Brazil, Vietnam, Russia, and Belarus. Several of these countries are considered high-risk for deforestation, which means importers must implement precise traceability procedures to track each raw material from origin to finished product. Better-managed supply chains improve early detection of disruptions or non-compliance, increasing resilience to market and regulatory risks.
Jakub Zombirt, senior director in consulting, JLL

Opportunities in New Challenges

Implementing the EUDR will entail costs—estimated at several billion euros annually across EU businesses, depending on the implementation scenario. At the same time, the regulation may accelerate investment in advanced warehouse management systems and drive modernisation across the sector. Beyond meeting regulatory requirements, such investments improve overall operational efficiency.

While the new rules pose challenges, they also offer opportunities for logistics providers to expand their services—supplier audits, documentation management, and end-to-end EUDR compliance oversight—strengthening their competitive position. For many companies, the first strategic step should be an EUDR supplier audit and a review of existing logistics contracts to clearly define responsibility for compliance.