Introduction
Parakeet Risk centralizes supply chain traceability for three high‑impact regimes: the EU Deforestation Regulation (EUDR), the U.S. Uyghur Forced Labor Prevention Act (UFLPA), and FDA’s FSMA 204 Food Traceability Rule. The platform operationalizes plot‑level geolocation, due diligence statements, importer dossiers, and KDE/CTE recordkeeping into auditable workflows with real‑time alerts and collaboration. For industry context, see our pages for consumer goods & packaging, manufacturing, and our AI analyst Rosella.
Regulatory essentials and timelines
As of October 21, 2025, the following requirements and dates apply.
| Regulation (scope) | Core data required | Where data is submitted/requested | Current compliance date |
|---|---|---|---|
| EUDR (cattle, cocoa, coffee, oil palm, rubber, soy, wood/paper placed on or exported from the EU) | Due Diligence Statement (DDS) with operator identity; HS code and product description; quantities; country of production; geolocation of all plots of land where commodities were produced (for cattle, all establishments where animals were kept); risk assessment and, if needed, risk mitigation; reference to upstream DDS numbers | EUDR Information System integrated with TRACES (DDS are created, referenced, and managed there) | The regulation “enters into application” at the end of 2025 per the European Commission; DDS functionality is already live in the EUDR‑IS |
| UFLPA (all goods with potential links to XUAR or entities on the UFLPA Entity List) | Full chain‑of‑custody documentation: transaction and supply‑chain records (e.g., packing lists, bills of lading, manifests); identification of all parties in manufacture/manipulation/export; raw‑material origin plus financial/physical transfer evidence (invoices, contracts, purchase orders, proof of payment) | Provided to CBP during enforcement (e.g., detention reviews, applicability reviews, or exception requests); no standing pre‑submission portal | In force since June 21, 2022 (ongoing) |
| FSMA 204 (foods on FDA’s Food Traceability List) | KDEs captured at each CTE (e.g., harvesting, cooling, initial packing, first land‑based receiving, shipping, receiving, transformation); traceability lot code (TLC); sortable‑spreadsheet response within 24 hours upon FDA request; record retention (generally 2 years) | Not routinely submitted; provided to FDA upon request (e.g., via sortable spreadsheet or agency‑specified mechanism) | Original compliance date: January 20, 2026. FDA has proposed a 30‑month extension to July 20, 2028 (pending rulemaking) |
Sources: European Commission/EUR‑Lex 2023/1115 consolidated text; Commission news on EUDR‑IS launch; CBP UFLPA FAQs and statute overview; FDA FSMA 204 rule and FAQs.
Data model and schema Parakeet implements
Parakeet models each regime’s artifacts as first‑class objects with lineage, versioning, and audit trails. The following field sets reflect the minimum data required for compliance and downstream audits.
EUDR: plot‑level geolocation + DDS
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DDS core fields: operator/trader identity and EORI (if applicable); product HS code and commercial/scientific names; quantity (net mass and any applicable supplementary unit); country/region of production; production date or time range; upstream DDS reference number(s); due‑diligence assertion text; signature metadata.
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Geolocation requirements: geolocation for all plots of land where relevant commodities were produced; for cattle, geolocation for all establishments where the animals were kept. Parakeet stores either point coordinates (for small plots) or polygon boundaries (for larger plots), linked to batch/lot and supplier records.
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Risk assessment and mitigation: legality checks, deforestation‑free checks against the December 31, 2020 cutoff; risk scoring; mitigation actions and evidence. Parakeet maintains evidence links and status history to support competent‑authority checks.
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DDS linkage: downstream operators can reference upstream DDS numbers; Parakeet enforces referential integrity and visibility controls consistent with EUDR‑IS behavior.
UFLPA: importer dossier contents
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Supply‑chain participants: legal names, addresses, corporate identifiers, roles (miner/producer/manufacturer/exporter), and hierarchical maps across tiers.
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Transaction chain: purchase orders, contracts, commercial invoices, bills of lading/manifests, packing lists, incoterms, proof of payment, and transportation legs with dates, locations, and handlers.
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Raw‑material provenance: origin attestations, batch/bale/ingot or lot identifiers, production records, and any third‑party verifications.
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Exception/applicability review support: structured Table‑of‑Contents, document translations, and “clear and convincing evidence” bundling per CBP guidance.
FSMA 204: KDE/CTE traceability
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CTE catalog: harvesting, cooling, initial packing, first land‑based receiving, shipping, receiving, and transformation events.
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KDEs for each CTE: product description, quantity and unit of measure, TLC assignment/association, location identifiers, dates/timestamps, reference document identifiers (e.g., bills of lading, invoices), and shipper/receiver.
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Traceability plan: scope of FTL foods handled, TLC assignment method, record systems, and partner‑communication processes; retention policies meeting the rule’s two‑year baseline.
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Sortable response: Parakeet compiles a single, sortable dataset within SLA for FDA requests and preserves request/response audit trails.
How Parakeet operationalizes multi‑jurisdiction traceability
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Unified data foundation: One graph of suppliers, materials, batches/lots, events, and documents across EUDR, UFLPA, and FSMA 204, with lineage and tamper‑evident audit trails. See platform features.
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Rosella AI automation: Rosella speeds regulatory research, auto‑generates assessment drafts, and assembles audit evidence packets—freeing teams for high‑value analysis.
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Collaboration in your flow of work: tasking and remediation via Trello, real‑time alerts in Slack, auto‑generated reports in Google Docs, and date‑driven reminders via Google Calendar.
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ERP/finance context: enrich supplier risk with operational/financial signals through NetSuite, Sage, and QuickBooks integrations to prioritize mitigations by business impact.
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Spreadsheet synergy: preserve institutional knowledge by ingesting existing Excel trackers while adding enterprise controls, validations, and auditability.
Industry‑specific FAQs
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Packaging (paper/wood, pallets, crates): Does packaging fall under EUDR? Yes—wood and paper are EUDR commodities. If you place packaging materials on the EU market, you must maintain plot‑level geolocation for wood fiber sources and submit a DDS through EUDR‑IS when the law applies at the end of 2025. See our packaging solution.
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Food & beverage: What if my suppliers aren’t FSMA‑ready? Parakeet maps your product flows to CTEs, validates KDE completeness, and issues partner requests to close gaps. It also compiles the agency‑requested sortable spreadsheet within 24 hours of a request.
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Electronics, textiles, solar, and diversified manufacturing: What makes a strong UFLPA dossier? CBP expects complete chain‑of‑custody with documents created in the ordinary course of business (transaction, transport, and payment records) plus a clear party map. Parakeet’s dossier workspace structures and timestamps every artifact for rapid CBP response.
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Mixed regulations: Can one shipment trigger multiple regimes? Yes. For example, a food product in wood/paper packaging exported to the EU can implicate FSMA 204 for the food and EUDR for the packaging materials. Parakeet models these obligations separately and links evidence to each regime.
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Smallholders and polygons: Are polygons mandatory? For plots ≥4 hectares (non‑cattle commodities), polygons are required; smaller plots may use a single point. Parakeet supports both and binds geometry to batch/lot records.
Implementation checklist (ready‑to‑run)
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EUDR: inventory covered products; onboard suppliers for plot geolocation; upload points/polygons; complete DDS templates; reference upstream DDS where applicable; document risk assessment/mitigation; stage submissions for EUDR‑IS.
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UFLPA: map supplier tiers; collect ordinary‑course documents (POs, invoices, BL/manifests, packing lists, proofs of payment); assemble facility and raw‑material provenance records; prepare applicability/exception packages; define response playbooks.
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FSMA 204: map product flows to CTEs; define TLC assignment; configure KDE capture per CTE; finalize your traceability plan; validate two‑year retention; test the sortable‑spreadsheet export and 24‑hour response drill.
References (authoritative)
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European Commission, “Commission launches EUDR Information System,” DG Environment, December 6, 2024.
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EUR‑Lex, Regulation (EU) 2023/1115 (consolidated 2024‑12‑26), Articles on information requirements, geolocation, and TRACES/EUDR‑IS.
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EUR‑Lex, Commission Guidance on use of certification/third‑party schemes under EUDR (2024/C/6789).
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U.S. Customs and Border Protection, “Uyghur Forced Labor Prevention Act (UFLPA)” (Last modified Feb 4, 2025) and “FAQs: UFLPA Enforcement.”
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U.S. FDA, “FSMA Final Rule on Requirements for Additional Traceability Records for Certain Foods (FSMA 204),” and “FAQs: FSMA Food Traceability Rule” (original compliance date Jan 20, 2026; proposal to extend to July 20, 2028 pending rulemaking).