EUDR due diligence in the wider landscape: OECD, CSDDD and the Forced Labour Regulation

The EUDR's due diligence is not an island. Its three operational steps under Article 8 (information collection, risk assessment, risk mitigation) are a commodity-specific instance of the OECD's six-step due diligence framework for responsible business conduct, which served as the template in the EU's legislative work. The OECD framework itself is not a legal requirement under the EUDR, but knowing the mapping helps a compliance team slot the EUDR case file into a wider programme.

The OECD six steps, mapped to an EUDR case file

• 1. Embed responsible business conduct in policies and management: the operator's DD system itself, with a compliance officer and an independent audit function for non-SMEs (Art. 11(2)).
• 2. Identify and assess adverse impacts: Art. 9 information collection and the Art. 10 risk assessment, per consignment.
• 3. Cease, prevent or mitigate: Art. 11 risk mitigation, until residual risk is negligible.
• 4. Track implementation and results: the annual review of the DD system (Art. 12(2)) and per-case freshness checks.
• 5. Communicate how impacts are addressed: the due diligence statement, the case file, and reporting (Art. 12(3) public reporting for non-SMEs).
• 6. Provide for or cooperate in remediation: corrective measures when non-compliance emerges, alongside the mitigation record.

What the Commission says about reuse

The 5th FAQ (May 2026) addresses this directly: a due diligence system established under the EUDR can support compliance with other EU due-diligence laws. The three-step EUDR process is helpful towards parts of the Corporate Sustainability Due Diligence Directive (CSDDD, applying from 26 July 2029) and the Forced Labour Regulation (applying from 14 December 2027). The reverse caveats matter too: CSDDD requires elements the EUDR does not, such as meaningful stakeholder engagement and a complaints procedure, and where the rules conflict, the EUDR prevails as lex specialis for the products it covers.

Practical takeaway: run the EUDR case file properly and most of the evidence, traceability and audit-trail work is reusable when CSDDD and FLR obligations arrive. Sylva's exports (case file, audit log, authority package) are designed to be that reusable record.