Sourcing raw material will likely be more challenging due to the current and potential supplier’s ability to comply with the regulation. Due diligence system should ensure geotags management and source transparency from each plot-of-land.
Evidence of geolocation by geotags and timestamps
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Plot of land/polygon/stamp approach
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Production at this plot-of-land is legitime
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Supply chain transparency
should be proved
Risk assessment
and mitigations
Along with the geotags, for each order came to EU market, the risk assessment should be performed by the company. All supply chain routes where there is a risk of non-conformance should be elaborated, assessed and mitigated. Only no and negligible risks are allowed.
Conformance and trust to the information about the geolocations.
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Risks of mixing the product on different routes, so each route to be assessed.
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Country risk level is important
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Yearly reassessments
Company suppliers should provide full information about the plots of land and routes how the product is delivered to EU. Information should be verifiable and provided along with the Annex forms.
The company is legally responsible for verification and reporting of this information.
Plots of land, and any proof
of evidence (i.e. photos
with geotags and timestamps)
―
Production time & date
―
Delivery routes in the supply chain
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Proofing documents:
invoices, certificates, etc.
Risk assessment module may include check-lists related to each location / route risks, documents and mitigation steps.