Sourcemap Inc.

Sourcemap provides state-of-the art software that allows global retailers, manufacturers and brands to map their supply chains down to the raw materials and ensure operational best practices every step of the way.

Lobbying Activity

Response to Delegated Regulation amending Annex I of Regulation (EU) 2023/1115 (EU Deforestation Regulation)

12 May 2025

As a company specialized in providing state-of-the-art software for global supply chain traceability, Sourcemap appreciates the opportunity to provide feedback on the draft Delegated Act revising Annex I of the EU Deforestation Regulation (EUDR). Sourcemaps software ensures compliance with supply chain due diligence regulations by mapping and monitoring upstream suppliers and verifying chain of custody data from raw material to finished products. As such, we are an essential link in the implementation and compliance of the obligations provided in the EUDR. Our feedback concentrates on the problems related to relevant products made from non-relevant commodities. In this regard, we welcome the clarifications brought by the draft Delegated Act, notably by making the exclusion of relevant products made from non-relevant commodities from the scope of the Regulation clearer. We insist that the differentiation between synthetic products and natural ones (e.g. synthetic and natural rubber), which bear the same HS code, must be clearly designated in EU TRACE. However, while we see the draft Delegated Act as positive step, we deem it insufficient in ensuring a smooth functioning of the EUDR for operator placing non-relevant products with HS codes listed in Annex I. As synthetic and natural products bear the same HS code, uncertainty and concerns still remains for operator regarding the way customs authority will be able to distinguish between the products, and on the way checks will be enforced. Thus, we call on the European Commission to publish guidance for operators on the type of evidentiary documents they should provide to prove a products non-relevance and exemption from the scope of the EUDR. We thank the European Commission for its consideration and remain available to discuss this issue and potential solutions further.
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Meeting with Maria-Manuel Leitão-Marques (Member of the European Parliament, Rapporteur) and BUSINESSEUROPE

26 Apr 2023 · Forced Labour

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and

8 Mar 2023 · Corporate Sustainability Due Diligence

Meeting with Jan Huitema (Member of the European Parliament, Shadow rapporteur)

2 Feb 2023 · ESPR and digital product passport