EUDR

The EU Deforestation Regulation (EUDR)

The EU Deforestation Regulation (EUDR) is a key element of the European Union’s sustainability agenda, aimed at reducing the EU’s contribution to global deforestation and forest degradation. The Regulation seeks to promote deforestation-free supply chains.

The EU Deforestation Regulation (EUDR) is a key element of the European Union’s sustainability agenda, aimed at reducing the EU’s contribution to global deforestation and forest degradation. The Regulation seeks to promote deforestation-free supply chains.  

What is the EU Deforestation Regulation (EUDR)?  

The EUDR aims to reduce EU’s contribution to global deforestation, reduce carbon emission and address illegal deforestation and forest degradation.  

Products may only be placed on, made available on, or exported from the EU market where they are: 

• They are deforestation-free (cut-off date: 31 December 2020) 

• Thet have been produced in accordance with relevant legislation of country if production  

• They are covered bu due diligence statement (to be submitted in Information System set up by Commission) 

EUDR applies to primary feedstocks for the oleochemical and surfactant industries: palm and palm kernel oils, and some derivatives. 

The EUDR requirements apply to:

• Relevant Commodities: cattle, cocoa, coffee, palm oil, rubber, soya and wood; and

The EUDR also covers certain products derived from these commodities, such as selected palm oil based derivatives. A list of in-scope products is displayed in Annex I of the EUDR. Products are identified by their Combined Nomenclature (CN) codes.

See APAG’s one pager on Annex I, here.

Under the EU Deforestation Regulation (EUDR), companies are mainly classified as either operators or traders. This distinction is important because it determines the level of compliance obligations. Here is an overview of the different roles:

• “operator” means any natural or legal person who, in the course of a commercial activity, places relevant products on the market or exports them.
• ‘micro or small primary operator’ means an operator who is a natural person or a micro-undertaking or small undertaking, within the meaning of Article 3(1) and Article 3(2), first subparagraph, respectively, of Directive 2013/34/EU of the European Parliament and of the Council (¹ ), irrespective of its legal form, established in a country classified as low risk in accordance with Article 29 of this Regulation, and who, in the course of a commercial activity, places on the market or exports relevant products that this operator itself has grown, harvested, obtained from or raised on relevant plots of land, or, as regards cattle, on establishments located in that country; (…)
• “downstream operator” means any natural or legal person who, in the course of a commercial activity, places on the market or exports relevant products made using relevant products, all of which are covered by a due diligence statement or by a simplified declaration.
• “trader” means any person in the supply chain other than the operator or downstream operator who, in the course of a commercial activity, makes relevant products available on the market.
• ‘authorised representative’ means any natural or legal person established in the Union who, in accordance with Article 6, has received a written mandate from an operator to act on its behalf in relation to specified tasks with regard to the operator’s obligations under this Regulation;

Before placing products on the market or exporting them, companies must exercise due diligence and submit a Due Diligence Statement.

The due diligence process includes three key steps:

1. Information Collection: Gathering data demonstrating compliance.
2. Risk Assessment: Assessing whether there is more than a negligible risk of non-compliance.
3. Risk Mitigation: Taking proportionate measures where risks are identified, including audits, supplier engagement, or additional controls.

Companies must maintain a due diligence system, review it regularly, and retain records for at least five years.

Operators are required to collect extensive supply chain information, including:

• Product description and quantity
• Country of production
• Supplier details
• Evidence of legal compliance
• Geolocation coordinates of all plots of land where relevant commodities were produced

This traceability requirement is central to the EUDR framework.

The EU Commission is introducing a benchmarking system classifying countries and regions as:

·         Low Risk

·         Standard Risk

·         High Risk

Products sourced from low-risk countries may benefit from simplified due diligence requirements, while products from standard- and high-risk origins will face increased scrutiny.

You can find the Country Benchmarking published in May 2025) here.

EU Member States are responsible for enforcement through designated competent authorities.

Penalties for non-compliance may include:

• Significant financial penalties
• Confiscation of products or revenues
• Temporary exclusion from public procurement
• Prohibition on placing products on the EU market
• Corrective actions or product recalls

In December 2024 and December 2025 the European Union amended the Deforestation Regulation, introducing simplification measures which will reduce administrative costs and burden for companies covered by the Regulation.

The entry into application is:

• Large and medium operators: 30 December 2026
• Micro and small operators: 30 June 2027
• Micro and small operators already covered by the EU Timber Regulation (EUTR): 30 December 2026.