EUDR Declaration in Excess: Understandings and Usage Scenarios

March 28, 2025

ISEAL commissioned SCS to examine how “declaration in excess” is understood and used by supply chain actors to comply with the EU Deforestation Regulation (EUDR). Interviews with stakeholders in palm oil, coffee and rubber revealed varying levels of awareness, implementation strategies and potential hurdles. The report highlights different interpretations and implementations of declaration in excess, assessing both potential benefits and challenges from a regulatory and business perspective.  

Summary of Findings

Under EUDR, companies – from production of raw material to the point of entry into the EU – must track the exact origin of compliant materials (soy, wood, palm oil, coffee, cocoa, beef and rubber) throughout the supply chain. In an interconnected economy and globalized market, allowing the declaration of all possible plots of origin in a given shipment rather than the actual plots of origin, i.e. declaration in excess, is critical for organizations to meet EUDR. Declaration in excess is applied by operators – they fill out due diligence statements – but the concept is applicable upstream, e.g., compliant smallholder production collected and mixed with other smallholder production.  

The key take-aways of this report are:  

• A large portion of supply chain actors are unfamiliar with declaration in excess, but the concept is not novel – “aggregate traceability” is an approach many certification schemes enable when grouping producers together under a single certificate.    
• There are trade-offs to using declaration in excess – it may be to the benefit of one supply chain actor (such as large growers, smallholders, brand owners, intermediaries, importers/exporters, governments, or voluntary schemes) and significantly encumber another.  
• The main advantages of declaration in excess include adaptability, cost effectiveness, smallholder inclusion and market access, practicality, and complementarity with sustainability certification schemes
• The main drawbacks of declaration in excess include interconnectedness and the risk of contamination, misunderstanding of the concept, reliability on data, consumer expectations, and technological limitations. 

Even though declaration in excess only technically applies to operators (those importing to the EU), “aggregate traceability” can be employed by any supply chain actor. This may not be an appropriate approach for all supply chain actors – it is largely dependent on where they are in the supply chain and the level of risk they are willing to accept for themselves and pass downstream to their buyers.   

Learn more and download the full report from the ISEAL website at: https://www.isealalliance.org/sustainability-news/deforestation-free-supply-chains-role-declaration-excess