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 | HOST Andy Simmons
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| GUEST SPEAKER Alex Lowery
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Episode 3: EUDR, Forced Labor, and the Shift from Declaring to Proving
The EUDR takes effect at the end of 2026, with the EU forced labour regulation following a year later. Both measures push beyond declaring goods and providing the right information, toward tracing and proving a company's whole supply chain. In episode three of Global Trade Lens, host Andy Simmons talks with Alex Lowery, Senior Solutions Consultant for Global Trade Management in Europe at e2open, about how years of constant disruption have changed how European trade teams work, why tariff volatility has companies rethinking sourcing and free trade agreements, and where AI genuinely helps versus where a human still needs to own the call.
Key insights from this episode
Why disruption, from Brexit through COVID to the current run of tariffs, has made regulatory agility a permanent requirement for European trade teams rather than a one-time adjustment
Where AI already helps with trade document processing and classification support, and why product classification still requires human judgment
How the EUDR and EU forced labour regulation raise the bar for supply chain traceability and documented proof
Why master data, rather than AI alone, determines whether digital transformation can actually deliver value
How years of disruption changed European trade compliance
Lowery entered global trade during the chaos that followed Brexit, when UK firms that had never filed a customs declaration suddenly had to. That steep learning curve set the tone for what came next. What followed was a steady succession of shocks, from COVID and the war in Ukraine to conflict in the Middle East and a fast-changing set of US tariffs, making it more complex and expensive to move goods across borders almost everywhere at once.
Lowery notes that large, complex companies in the US, the EU, and Asia now face strikingly similar pressure, because their supply chains are global enough that a disruption anywhere touches all of them. That shared exposure has pushed trade compliance out of the back office and onto the executive agenda, since the cost of getting it wrong has grown too large to leave to a single department.
The EUDR and EU forced labor regulation: from declaring to proving
The EUDR takes effect at the end of 2026, requiring companies to trace products within their supply chain and maintain a documented audit trail rather than simply declaring goods and supplying the right paperwork.
The EU forced labor regulation follows a year later, giving companies more time to prepare but asking for the same shift in kind. Both rules move compliance from declaring and providing information toward tracing and proving a supply chain, a distinction Lowery describes as a genuinely different type of compliance, not just more of the same.
Where AI helps in trade compliance, and where a human still decides
AI already earns a place in a couple of specific spots for Lowery. Trade documentation tends to be messy and unstructured, and AI can clean it up and structure it for use in a compliance process. Product classification is the second case, where AI can suggest a classification from a spec sheet and help a classifier move faster, but the final call still belongs to a person. Getting a classification wrong carries real duty and regulatory consequences, so it has to be correct every time, and AI is not there yet.
"Even with the best GTM system and the slickest processes, if you have poor master data behind it, you are just not going to be able to deliver any value."
- Alex Lowery, Senior Solutions Consultant, e2open
The real foundation of digital transformation: clean master data
Asked what he would wish for on behalf of clients, Lowery does not reach for AI. He wants clean, accurate master data, the product, partner, and supplier information that sits underneath every other capability. Large organizations often start from a tangle of country-specific operations and a dozen or more ERP systems, while smaller companies may simply have a less mature trade compliance function. Either way, Lowery's advice is the same: get the foundation right, including people, process, and culture alongside the data, before expecting any platform to deliver results on its own.
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FAQ Section
What is the EUDR?
The EUDR, or EU Deforestation Regulation, takes effect at the end of 2026. It requires companies placing certain commodities, including wood, cocoa, coffee, soy, rubber, palm oil, and cattle, on the EU market to prove those goods were not produced on land deforested after a set cutoff date. That proof requirement distinguishes the EUDR from earlier trade rules by requiring documented evidence about product origin and deforestation risk across the supply chain.
What is the EU forced labor regulation?
The EU forced labor regulation (also written as the EU forced labour regulation) takes effect at the end of 2027, a year after the EUDR, and bans products made with forced labor from the EU market. Companies will need documented supply chain evidence capable of supporting claims about where and how goods were produced.
How is the EU forced labor regulation different from the UFLPA?
The EU forced labor regulation and the United States' Uyghur Forced Labor Prevention Act, or UFLPA, share a common goal, removing forced labor from supply chains, but they are separate laws with separate scopes, timelines, and enforcement bodies. The UFLPA presumes goods connected to Xinjiang, China, were made with forced labor unless an importer proves otherwise, while the EU regulation applies more broadly to products entering the EU market regardless of origin. Companies selling into both regions need to track both sets of requirements rather than assume compliance with one satisfies the other.
What is supply chain traceability?
Supply chain traceability means having visibility into where a product's components and materials came from and how they moved through a supply chain, often several tiers deep. The EUDR and the EU forced labor regulation both require this level of visibility, since proving a claim about deforestation or forced labor depends on documented, verifiable supply chain data rather than a supplier's word alone.
Where does AI actually help in trade compliance today?
AI already helps with two specific parts of trade compliance: turning messy, unstructured trade documents into clean, structured data, and suggesting a product classification based on a spec sheet or data sheet to help a classifier work faster. Neither use case removes the person from the process. Classification carries direct duty and regulatory consequences, so a human still has to own the final decision, and Lowery expects that to remain true for the next several years even as the underlying models improve.
Why does master data matter more than any single software platform?
Master data is the product, partner, and supplier information that every other trade compliance capability depends on. Even the most capable global trade management system will struggle to deliver value if the master data behind it is incomplete or inaccurate, since classification, screening, and origin determinations all rely on that data being correct in the first place. Lowery's advice to clients starting a digital transformation is to treat clean master data, not new software, as the actual foundation of the project.
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