What exactly is EUDR, who does it apply to and what does it mean for European importers? In this article, I explain the most important assumptions, obligations and changes introduced in 2025 to help businesses understand the new regulatory reality.
Regulated products and raw materials
The scope of the EUDR covers key commodities identified as risky in terms of deforestation. Annex I of the regulation lists specific raw materials and products made from them. These include:
- Bydło (and derived products such as beef, leather and leather products),
- Cocoa (e.g. cocoa beans, chocolate),
- Coffee,
- Palm oil (and its derivatives and vegetable oils from palm),
- Soybean,
- Natural rubber (rubber) and
- Wood (and wood products, e.g. lumber, charcoal, paper, furniture).
The regulation also covers processed products containing these raw materials, such as chocolate, furniture, paper, rubber products, printed paper, preserved meat, leather and leather products. This list may be extended – the European Commission is to periodically assess other raw materials and, if necessary, propose their regulation.
Obligations of operators and traders
The EUDR Regulation imposes requirements on all economic operators who place covered products on the EU market or export them outside the Union. Market participants are divided into two main categories:
- "Operators" – i.e. entities that for the first time introduce a given good or product to the EU market (e.g. importers, producers in the EU), and
- "Trading entities" (traders) – i.e. entities dealing with further turnover products already introduced to the market (e.g. wholesalers, retail chains).
Each operator bears full responsibility for the compliance of their goods with the requirements of the regulation. In practice, this means that they must carry out due diligence and make an official declaration confirming that the product complies with the EUDR. Traders, on the other hand, must ensure that the products they trade have undergone due diligence by previous operators. The extent of their obligations depends on the size of the company: large traders (which are not SMEs), such as supermarket chains, are subject to the same requirements as operators – they must submit their own due diligence declarations (they may rely on analysis previously carried out in the supply chain, but they are still liable for any non-compliance). Small and medium-sized traders are exempt from carrying out due diligence themselves for products that have previously undergone this procedure – but they must keep and make available for 5 years the required information on suppliers, products and their compliance upon request by supervisory authorities. Regardless of the role in the supply chain, no product covered by the EUDR may be placed on or exported from the EU market if it does not comply with the regulation.
Scope of Due Diligence Required
Operators introducing regulated goods must conduct a thorough due diligence process to ensure that the products are deforestation-free and legal. The regulation specifies a number of steps that constitute due diligence. Key elements of this process include:
- Collecting detailed information – the company must collect data on each product and batch of goods: description and quantity of the raw material, supplier details, country (and region) of origin of the raw material, as well as precise geographical coordinates of the plot (or farm) from which the raw material comes. It is also necessary to document the date of production/harvest in the context of the cut-off date of 31.12.2020.
- Risk assessment – based on the information collected, the operator must analyse the risk that a given raw material may come from an area deforested after the cut-off date or that it violates legal regulations. The complexity of the supply chain, the country of origin (and its risk category), potential attempts to circumvent regulations or mix raw materials from different sources must be taken into account. If the raw materials come from countries considered by the EC as low risk, a simplified due diligence procedure may be applied. In the case of high-risk sources, tightened control measures will be required.
- Implementation of countermeasures – if the assessment reveals any risk of non-compliance greater than negligible, the company must take action to reduce this risk to a negligible level before introducing the product to the market. This may include, for example, additional supplier audits, changing the source of supply, obtaining additional certificates or information. If the risk cannot be reduced to zero (negligible), the product cannot be introduced to the market.
After completing the above stages, the operator is required to prepare and submit a Due Diligence Statement in a special electronic system. Submitting such a statement is a condition for allowing a given batch of goods to be released for circulation – in the statement, the company officially confirms that it has exercised all due diligence and has not identified more than a negligible risk that the product has contributed to illegal deforestation or violates the law. The received statement reference number must then be provided in customs declarations (when importing or exporting) and shared further in the supply chain. The due diligence system must also be regularly reviewed (at least once a year) and updated by the company in accordance with Article 12 of the EUDR.
Obligation to geolocate and provide proof of legal origin
One of the most stringent requirements of the EUDR is full traceability of the origin of raw materials down to the land parcel level. The regulation requires that for each batch of covered goods, the operator collects the geographical coordinates (longitude and latitude) of the plots on which the raw material was produced. This information must be included in the due diligence declaration and transferred to the EU IT system. There are no exceptions to the geolocation obligation - it applies to all deliveries, regardless of the country of origin or the size of the producer. This requirement is to allow authorities to verify (e.g. using satellite data) that no deforestation has occurred in the declared cultivation area after the specified cut-off date.
The second pillar of compliance is the legality of production at the place of origin. The EUDR requires that products are manufactured in accordance with the “applicable legislation of the country of production” – this means compliance with all local regulations, including those relating to forest management, land use, land tenure, environmental protection, labour rights and the rights of indigenous people. The operator must gather evidence of legality – this could be, for example, permits from local authorities for land conversion, documents confirming legal land acquisition, certificates of origin, audit reports or court rulings. These documents serve to document compliance as part of the risk assessment and are also subject to verification. Ultimately, any product placed on the EU market must meet three cumulative conditions: be deforestation free, in accordance with the law of the country of origin and covered by due diligence statement. Failure to meet any of them means that the goods cannot be legally sold in the EU.
Effective Dates and Schedule Changes (2025)
Regulation 2023/1115 (EUDR) entered into force on 29 June 2023, but a preparatory period of several months was foreseen before it would start to apply. Initially, the regulations were to apply from 30 December 2024 for large companies, and from 30 June 2025 for small and micro entities. However, Member States and entrepreneurs have signalled serious difficulties in implementing the EUDR in such a short time – among others due to the need to build from scratch IT systems to handle declarations, conduct benchmarking of countries of origin (risk classification) and develop detailed technical guidelines. In response to these concerns, the European Commission proposed in October 2024 to postpone the date of application of the regulation by one year.
After accelerated legislative negotiations, the decision to change the timetable was taken at the end of 2024 – the European Parliament approved the extension of the time for adaptation on 17 December 2024, and the Council of the EU formally adopted it on 18 December 2024. The amended regulations were published in the Official Journal before the end of the year, thanks to which the change entered into force in 2024. As a result, the application of the EUDR was postponed by 12 months – currently, large companies must comply with the new requirements from 30 December 2025, and micro and small companies from 30 June 2026. Additionally, it was established that the Commission has until the end of June 2025 to prepare and implement a system for classifying countries of origin (so-called benchmarking), dividing them into risk categories. This means that the countries of origin of raw materials will be assigned to the low, standard or high risk category at the latest six months before the start of application of the EUDR.
The decision to delay gave companies and administrations additional time to prepare, which is supposed to increase the chances of successfully implementing the new requirements. At the same time, this solution caused some controversy, with environmental organizations criticizing the delay in forest protection activities, and some politicians fearing that small companies may still have difficulties implementing the obligations without further facilitations.
Simplifications proposed in 2025 (Omnibus package)
In 2025, EU institutions took broader action to simplify regulations in the area of sustainable development and give companies more time to adapt. On February 26, 2025, the European Commission announced the so-called “Omnibus I” package – the first set of legislative proposals simplifying ESG requirements for companies. This package proposed, among others, changes to the CSRD (sustainability reporting) and CSDDD/CS3D (corporate due diligence directive), the CBAM mechanism and other acts, along with a mechanism called “Stop-the-Clock”. The “Stop-the-Clock” mechanism provided for the official postponement of the implementation deadlines for new obligations, which primarily covered the CSRD and CSDDD reporting requirements (by 2 years and 1 year, respectively).
As regards the EUDR Regulation, the issue of extending its application date was de facto decided in a separate procedure already in 2024 (as described above). This was part of the Commission's broader approach to relieve businesses and enable a smoother implementation of the new rules. Importantly, the adopted changes do not interfere with the objectives or substance of the regulation - only the cut-off dates were postponed, leaving the substantive requirements of the EUDR unchanged. During the negotiations, the European Parliament suggested additional simplifications, such as the establishment of a category of countries "without risk of deforestation" (whose imports would be partially exempt from obligations) in order to reduce the burden on companies importing goods from such countries. However, these proposals did not receive support from the Council and were ultimately limited to changing the deadline for the regulation.
As part of the compromise agreed at the end of 2024, the European Commission has additionally committed to reviewing the effects of the EUDR and possible further simplifications by 2028. This means that the administrative costs and efficiency of the new rules will be monitored in the following years, and by the end of 2028 the Commission will assess whether changes are needed to reduce bureaucracy or clarify requirements for companies. In parallel, in 2024-2025, the EC launched a special EUDR IT system (based on the TRACES platform) for submitting due diligence declarations and an online training program for companies to help them meet their new obligations. All these actions are aimed at ensuring that, despite the strict requirements of the regulation, its implementation will be as efficient and effective as possible for both authorities and economic operators.
Sectors and supply chains particularly affected by changes
The EUDR will affect a wide range of industries, but the most affected will be companies importing and using regulated raw materials and their extended supply chains. This will primarily concern the agri-food sector (importers of palm oil, soybeans, coffee, cocoa; food and beverage producers using these ingredients, e.g. producers of confectionery, chocolate products, coffee and soy products), the meat and leather industry (beef farmers and processors, producers of leather and leather products - raw cattle), the wood and paper industry (importers of wood and wood products, furniture, paper and cellulose producers) and the rubber industry (importers of natural rubber, producers of rubber products and tires). Large international companies trading in raw materials (traditional trading companies) and global retailers selling agricultural products will also be among the most obliged to adapt procedures.
Global Supply Chains – especially those reaching into regions known for their high risk of deforestation, such as the Amazon, Southeast Asia or the Congo Basin – will have to be reorganised in terms of full transparency. Companies will be forced to obtain very detailed information from even the smallest suppliers (e.g. small farmers in the tropics), which is a major logistical and technological challenge. Concerns were raised already at the development stage that collecting data on the origin of raw materials and verifying it in such complex supply chains is an extremely difficult task for many entities. For example, the need to map thousands of farms supplying cocoa beans or coffee and checking each for deforestation requires the use of geoinformation tools on an unprecedented scale. Companies will have to invest in traceability systems, work closely with foreign suppliers and in some cases seek alternative sources of supply if the current ones are associated with the risk of non-compliance.
Supply chains linked to deforestation areas will be most at risk of non-compliance – and there is expected to be increased scrutiny by authorities. For example, it has been pointed out that imports of natural rubber from West and Central Africa may pose a threat to tropical rainforests, just as imports of cattle hides from South America (used, among other things, to produce gelatin and collagen) contributed to deforestation in Paraguay. In such cases, companies will have to show special care, and potentially change suppliers or cooperate on projects that ensure sustainable agricultural practices.
Large enterprises with resources will be relatively better prepared to cope with the EUDR – many of them have been implementing sustainable sourcing systems for some time now. Smaller companies may feel the new regulations more acutely due to limited possibilities to obtain data from foreign suppliers and administrative costs, hence the postponement of the deadline for them until 2026 and some simplifications have been provided. Nevertheless, all importers and exporters of goods listed in the EUDR must prepare for significant changes. It is expected that in 2025-2026 many companies will review their supply chains, establish closer cooperation with suppliers (e.g. through training programs for farmers, certifications, satellite monitoring of crops) and introduce internal procedures for compliance with the EUDR. Thanks to this – despite initial difficulties – the regulation has a chance to achieve the intended effect of reducing the EU market's share in global deforestation while promoting sustainable business practices.
If you need more details or support in adapting to the new requirements, please contact me.
katarzyna.cieslik@greenreporting.eu
by phone: 533 424 695
