Regulatory compliance

EUDR, CBAM & CS3D

Three major EU regulations reshaping market access conditions for MERCOSUR exporters. Understanding their requirements has become essential.

Overview

The European Union has adopted three cross-cutting regulations that apply independently of the EU-MERCOSUR agreement but directly impact bilateral trade flows.

EUDR

Deforestation Regulation (EU) 2023/1115

Prohibits placing on the EU market products linked to deforestation or forest degradation after 31 December 2020. Operators must prove their products are 'deforestation-free' through a due diligence system.

30.12.2026 (grandes entreprises) / 30.06.2027 (PME)
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CBAM

Carbon Border Adjustment Mechanism (EU) 2023/956

Imposes a carbon price on imports of certain carbon-intensive products. Aims to prevent 'carbon leakage' and ensure competitive fairness between EU producers (subject to ETS) and importers.

01.01.2026 (phase définitive — certificats CBAM obligatoires)
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CS3D

Corporate Sustainability Due Diligence Directive (EU) 2024/1760

Requires large companies to identify, prevent and mitigate adverse impacts on human rights and the environment throughout their value chain, including at their suppliers in third countries.

26.07.2027 (> 5 000 employés) / 26.07.2028 (> 3 000) / 26.07.2029 (> 1 000)
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Affected products

  • Soy and derivatives
  • Beef and leather
  • Coffee
  • Wood and wood products
  • Palm oil
  • Rubber
  • Cocoa

Key obligations

  • Geolocation of production plots
  • Full supply chain traceability
  • Due diligence statement before import
  • Verification through a dedicated information system (EU IS)

Sanctions

  • Fines up to 4% of annual EU turnover
  • Confiscation of products and revenues
  • Exclusion from public procurement

MERCOSUR exposure

Very high — Brazil is the world's largest exporter of soy and beef. Argentina, Paraguay and Uruguay are also major agricultural exporters. MERCOSUR accounts for a significant share of EU imports of deforestation-risk products.

Règl. (UE) 2023/1115EUR-Lex
Application timeline

Application timeline

01.10.2023CBAM

CBAM — Transitional phase (declarations)

01.01.2026CBAM

CBAM — Definitive phase (mandatory certificates)

30.12.2026EUDR

EUDR — Application for large/medium enterprises

30.06.2027EUDR

EUDR — Application for SMEs

26.07.2027CS3D

CS3D — Companies > 5,000 employees, turnover > €1.5bn

26.07.2028CS3D

CS3D — Companies > 3,000 employees, turnover > €900m

26.07.2029CS3D

CS3D — Companies > 1,000 employees, turnover > €450m

The rebalancing mechanism

The EU-MERCOSUR agreement includes a rebalancing mechanism (Art. X) allowing MERCOSUR to request consultations if CBAM, EUDR or other unilateral EU measures create a disproportionate impact on their exports. This mechanism can lead to compensatory adjustments.

Compliance strategies

Compliance strategies

Map your exposure

Identify which products, suppliers and trade flows are affected by each regulation. Prioritise by volume and risk.

Document the supply chain

Collect geolocation data (EUDR), emissions data (CBAM) and impact assessments (CS3D) from your MERCOSUR suppliers.

Engage your MERCOSUR partners

Train your suppliers on EU requirements. Include compliance clauses in your contracts. Support them in implementing traceability systems.

Anticipate the rebalancing mechanism

Monitor developments of the EU-MERCOSUR agreement's rebalancing mechanism that could offset the impact of CBAM and EUDR on MERCOSUR exporters.

Need a compliance audit?

We analyse your exposure to EUDR, CBAM and CS3D regulations and develop a compliance roadmap tailored to your business.

Request an audit