Compliance
The proof is filed
before it sails.
Two of the three regimes governing this corridor are enforceable today; the third carries a date. What they share is that the evidence has to exist before the goods do — a filed statement, a verified chain, a score you can defend. Nothing is produced after the fact.
A Due Diligence Statement has to be filed before regulated goods enter the EU, with geolocation for every plot the material came from.
US Customs works from a presumption of forced labour on exposed supply chains. Rebutting it is the importer’s job, and the evidence has to exist when the container lands.
Larger companies will have to show documented supply-chain due diligence. Firms building that evidence base from nothing are quoting six to eighteen months.
Source Regulation (EU) 2023/1115 (EUDR, in force 2025) · UFLPA (enforced by CBP from 2022) · Directive (EU) 2024/1760 (CSDDD, applicable from 2027).
Three regimes
Each one wants
the evidence first.
The dates are the dates — none are projected. Two are already enforceable; the third is on the calendar. Read each for what it actually obliges, not the slogan.
EU Deforestation Regulation
In forceRegulation (EU) 2023/1115
Applies to seven commodity categories including cattle, cocoa, coffee, palm oil, soy, wood, and rubber. EU operators must file a Due Diligence Statement (DDS) before placing regulated goods on the EU market. Failure to comply risks fines of up to 4% of annual EU turnover and market access suspension.
Key obligations
- Applies to cattle-derived leather from Argentina
- Cotton and synthetic textiles: exempt from EUDR scope
- DDS filed via TRACES NT portal before import
- Geo-polygon data required for each farm in the supply chain
- Article 4 obligation rests with the EU operator of record
What Merco does
Merco handles geo-polygon collection, satellite deforestation checks, DDS drafting, and TRACES NT filing. You review and approve each document before submission. The Article 4 due diligence decision remains yours as EU operator.
How a claim is proved
Seven checks,
run in order.
Before a supplier is listed, the same sequence runs on every record — geo-polygons, the DDS, the origin rule, entity screening, certifications, identity. It resolves to one score and a hash you can look up. The criteria are fixed; they are not adjusted per deal.
EUDR geo-polygons
···DDS drafted & filed
···CSDDD risk score
···Rules of Origin
···UFLPA / CBP screening
···Certification audit
···KYB identity
···Worked example — SUP-4471 and the score are illustrative; the seven checks are the real verification sequence run on every supplier. Methodology: /compliance/methodology.
One score
Every check,
one number.
The Compliance Brain is deterministic — it re-runs on every document and resolves to a single score, with each underlying check and a verifiable hash shown against the supplier. Nothing about it is a black box.
- One deterministic scorerecomputed on every document
- Satellite-confirmeddeforestation · 0.0 ha
- Certificate authenticitychecked against issuer registries
Rules of origin
Where “in territory”
begins.
To claim the preferential rate, the good has to be made in the territory — not just shipped from it. For EU list rules that means manufacture from yarn: the yarn may be imported, but the cloth and the garment must both be formed and made up in territory. Two transformations. The cut line marks where “in territory” begins; everything below it must qualify.
Claiming EUR.1 needs double transformation — fabric formation and making-up both in eu / mercosur territory. Yarn and fibre may cross borders; the cloth and the garment may not.
Source EU list rules of origin, Ch. 50–63 (manufacture from yarn); EU–Mercosur Agreement, product-specific rules of origin. Rules-as-code in lib/origin/rules.ts.
EU–Mercosur · HS 61/62
Twelve to zero,
on a schedule.
Apparel duty phases from the 12% MFN baseline to 0% over ten years from January 2026, in annual steps. The line is a staircase, not a curve — the rate only moves on the year. Colombia is already at 0% under the EU–Colombia agreement, since 2013.
Source EU–Mercosur Agreement, apparel HS 61/62 staging category (12% → 0%, 2026–2035); MFN rate from EU TARIC (HS 6109.10).
Colombia sits at 0% today under the EU–Colombia FTA (single transformation). Importers declare origin and file the proof at customs — an EUR.1 issued by the exporting country, or a registered-exporter (REX) self-declaration; Merco calculates the applicable rate at order time.
Scope
What we run.
What stays yours.
Merco runs
- Supplier discovery, verification and ranking
- EUDR plot verification from satellite record
- DDS drafting and filing to TRACES NT
- Rules-of-origin documentation and landed cost
- Freight booking and tracking to port
- Escrow, milestone releases and the ledger
- Document storage and the audit trail
You keep
- Commercial ownership of the order
- Final choice of supplier
- Quality inspection and acceptance
- Your customs import declaration
- Import duty and VAT
- Operator-of-record obligations
We are the workflow layer, not the regulatory guarantor. Obligations under EU and US import law remain with the importing entity.
Open the route.
Tell us what you buy and where it lands. We come back with factories that can make it and the paperwork position for each one. No fee to join.