What is circumvention and how to spot it in your supply chain?

Last updated: October 16, 2025

What is circumvention?

The EU Deforestation Regulation (EUDR) doesn’t just require traceability to the origin of commodities, it also blocks attempts to hide that origin.

  • Circumvention happens when companies try to hide the real origin of a product by moving it through another country

The goal is usually to make a product look like it came from a low-risk country, when in fact it was produced in a high or medium risk country, or its origin is unknown.

Common circumvention methods

Here are some common ways circumvention might happen:

Method

Description

Why its risky

Re-export via trading hubs

Raw material is shipped through a country like Turkey, then exported to the EU with that country listed as the 'origin'

These countries are often not the actual place of production, just a stopover

Blending at ports

Commodities from multiple origins are mixed before shipping

This can hide high-risk sources and break traceability

Relabelling

The country of origin is changed on export documents

An EUDR violation, traceability must go back to the plot of land

Third-party intermediaries

Traders buy from unknown or risky sources and sell under their own name

You may lose sight of who originally produced the product

How to spot circumvention in your supply chain

Use these checks to identify possible risks:

Look at transit countries:

  • If your product passes through trading hubs like Turkey, Singapore, or UAE, verify whether they’re producing the commodity, or just handling exports.

Ask for farm-level data:

  • You should receive geolocation coordinates for where the product was grown, not just where it was exported from.

Check for origin changes:

  • If the country of origin seems to change late in the supply chain, ask why. If it’s just a port, that’s not enough.

Work with trusted suppliers only:

  • Use suppliers that are willing to share full sourcing documentation and traceability down to the plot.

Flag vague labels or origin claims:

  • Watch out for generic phrases like 'sourced from Asia” or 'mixed origin', these are not EUDR compliant.

What to do if you suspect circumvention

If you think a product in your supply chain may be circumventing EUDR rules:

1. Do not place the product on the EU market

Unless you have verified full compliance, with supporting documentation and risk assessment, the product should not be sold or imported.

  • Placing non-compliant products on the market is a breach of EUDR.

  • You are legally responsible for due diligence, regardless of what the supplier claims.

2. Request additional proof of origin

Ask the supplier for more detailed documentation to confirm the commodity’s origin:

  • Original farm plot data

  • Export permits from the country of production

  • Customs declarations showing the product’s full journey

3. Ask for a complete chain-of-custody trail

This could include a step-by-step log of all movements and transformations:

  • From the farm or producer

  • Through traders and processing facilities

  • To the port of export and on to your business

Check for consistency in locations, dates, and ownership changes.

4. Conduct enhanced due diligence

Use third-party tools or databases to verify:

  • Geolocation data

  • Supplier history

  • Customs data to cross-check declared vs actual origin

5. Consider switching to direct sourcing

If you regularly face documentation gaps or unclear supplier histories, consider sourcing directly from verified origin-level producers or through certified traceability systems.

IMPORTANT: Under EUDR, you are responsible for proving traceability, not your supplier. If origin data is missing or unclear, the product cannot legally enter the EU market.