Abstract

The European Union has assembled, over the last decade, the most ambitious agri-environmental compliance stack in the world. From the French loi sur le devoir de vigilance (2017) to the EU Deforestation Regulation (EUDR, 2023), the Corporate Sustainability Due Diligence Directive (CSDDD, 2024), the Ecodesign for Sustainable Products Regulation (ESPR, 2024) and the Soil Monitoring Law (2025), the regulatory surface that touches a single soybean shipment from Mato Grosso to a Lyon supermarket has expanded from a single customs declaration to a multi-layer due diligence file with geolocated polygons, deforestation cut-off proofs, supplier human-rights attestations, and verifiable provenance signatures. This note maps that stack, explains how the layers compose, and identifies the concrete openings through which a traceability platform can be recognised, not just used, by EU and French institutions, partners and operators.

Scope

Covers EU-wide regulation, French national specifics, and the voluntary standards that anchor agri-food traceability. Not exhaustive on sectoral fish, dairy, or organic regimes; those are referenced where they intersect the deforestation, due diligence and Digital Product Passport stack.

Research notes

• Timeline. Each instrument was added to fix what the previous one could not enforce. EUTR (2010) → French vigilance law (2017) → Green Deal (2019) → Farm to Fork (2020) → CSRD (2022) → EUDR (2023) → CBAM transitional (2023) → CSDDD (2024) → ESPR/DPP (2024) → Nature Restoration (2024) → Soil Monitoring (2025) → EUDR postponement (2025/2650) → Omnibus I recalibration (2025–26) → ETS2 trading 2028.
• EUDR deep dive. Seven commodities (cattle, soy, palm, cocoa, coffee, rubber, wood). Geolocation polygons ≥4 ha, single coordinates for cattle. Application from 30 December 2026 for large/medium operators after the December 2025 postponement; SMEs from 30 June 2027. Brazil classified as standard risk on 22 May 2025 (3% inspection rate). Only Belarus, Myanmar, North Korea and Russia in the high-risk tier. IS-EUDR runs on TRACES; only first operators file full DDS, downstream inherits the reference. Article 25 sets a floor of at least 4% of EU turnover for fines.
• Wider framework. CSDDD (post-Omnibus I): scope narrowed to >5,000 employees and >€1.5B turnover, application deferred to July 2029. CSRD now tightened to >1,000 employees / >€450M turnover. CSRD/ESRS demand structured supply-chain data in machine-readable XBRL. ESPR/DPP excludes food/feed/pharma in the first wave but the exclusion is under review. CBAM definitive regime from 2026, agri-relevant input is fertilisers. Nature Restoration national plans by Sept 2026. Soil Monitoring Law (Directive (EU) 2025/2360) in force since 16 December 2025.
• France. Loi 2017-399 binding in parallel with CSDDD (Casino litigation filed 2 March 2021, trial 2026). Égalim level-3 HVE only from Jan 2027 in public catering. Numagri/Agdatahub + GS1 France define the national agri-data semantic layer. ANSSI-listed eIDAS qualified trust services barely touch agriculture today.
• Operational realities. EUDR forbids mass balance; commodities must be physically segregated end-to-end. The indirect-supplier gap in Brazilian beef (85–90% of deforestation leakage) sits beyond SISBOV’s 90-day window and the G4 agreement’s slaughter-only coverage. Compliance cost is in the low six to low seven figures EUR/year per operator. The UK runs an analogous regime under Schedule 17 of the Environment Act 2021.
• Standards. GS1 EPCIS 2.0 + ISO 22005 are the reference data substrate. RTRS (cut-off May 2009 / June 2016) and ProTerra (cut-off January 2008) are stricter than EUDR cut-offs and broader on ecosystem coverage. Rainforest Alliance has shipped an EUDR alignment upgrade. PEFC has shipped a voluntary EUDR DDS module on top of Chain-of-Custody — a useful precedent for soy and beef equivalents.
• Trust infrastructure. EBSI Track & Trace is the natural anchoring layer for cross-border attestations. eIDAS 2.0 European Digital Identity Wallet adds qualified credential issuance.
• Where platforms fit. Six recognition tracks: (1) national semantic compatibility (Numagri/Agdatahub in France), (2) EBSI Track & Trace use case, (3) Horizon Europe Cluster 6 consortium, (4) integration with EUDR-aligned voluntary scheme as the data substrate beneath audits, (5) UK FRC dual-regime alignment, (6) French label co-build long-tail. CSDDD opens a separate “vendor of record” path once transposed in 2029.

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