With the effective date of the EU Deforestation Regulation (EUDR) being postponed again, some confectionery export companies have chosen to temporarily suspend their compliance efforts. However, industry insiders point out that for the confectionery industry, the real risks have not disappeared, only been delayed.
The confectionery supply chain is "long and fragmented," making compliance even more difficult
Compared to primary agricultural products, the typical characteristics of the confectionery industry are:
- Multiple raw material sources and deep supply chains
- High proportion of functional ingredients
- Frequent formula adjustments
This makes confectionery companies face more complex challenges under the EUDR framework – it's not simply a matter of "one raw material certificate" covering all product lines.
Especially for high-end confectionery, functional gummies, and chocolate products, their formulas often involve multiple regulated raw materials simultaneously.
The "hidden pressure" on small and medium-sized confectionery enterprises
Although the EU has extended the compliance deadline for small and medium-sized enterprises to June 30, 2027, the reality is:
- Small and medium-sized enterprises have weaker bargaining power with upstream suppliers
- They rely more on traders than direct sourcing from producers
- It is more difficult for them to obtain complete traceability data
Once their products are sampled and identified as high-risk, suspension of sales, fines, and product recalls will directly affect their survival.
The correct use of the extension period
Industry experts suggest that confectionery companies should prioritize three things during the extension period:
- Identify which SKUs involve EUDR raw materials
- Sign compliance responsibility clauses with suppliers
- Establish a separate "compliant product pool" for the EU market
