A Latin American agricultural exporter with a long-standing European customer base faced new EU rules requiring geolocation data and due diligence documentation for every consignment.
The company was sourced from several thousand smallholder producers through a cooperative structure. At the point the rules were announced, it could trace a delivery to the cooperative and no further. Several of its competitors were in the same position, and the trade association's early assessment was that a significant share of the country's export volume was at risk.
We worked on two levels simultaneously. With the client, we established what EU compliance required, which differed from the interpretation circulating in the exporting country. We helped build the documentation pathway, working back from the EU importer's obligations to what the exporter needed to collect at origin.
At the same time we engaged on the client's behalf in Brussels and in two national capitals during the implementation period. The client held information that officials could use about how the rules would land on smallholder supply chains, and we made sure it reached the people drafting the guidance. We arranged for the client's sustainability director to present at a technical stakeholder session and coordinated a joint submission with two European importers who shared the concern.
The implementation guidance addressed the cooperative aggregation question in terms the client's system could meet.
The exporter was compliant ahead of the application date. Two competitors from the same origin country lost European contracts during the transition, and the client absorbed part of that volume. It now runs traceability as a commercial argument with European buyers.