EUDR: understanding the EU Deforestation Regulation and preparing for compliance

Voluntary commitments are no longer enough to rule out deforestation risk in a supply chain. For wood, coffee, cocoa, soya, oil palm, rubber, cattle and the products derived from them, companies must be able to prove where their supplies come from, down to the plot of land on which they were produced.

 

This is the principle behind Regulation (EU) 2023/1115, commonly known as the EU Deforestation Regulation (EUDR), which targets both deforestation and forest degradation.

 

The Regulation was adopted on 31 May 2023 and entered into force on 29 June 2023. Its application has since been postponed twice. The obligations, originally due to apply from 30 December 2024, were first deferred by one year through an amending regulation adopted in December 2024, then postponed again by Regulation (EU) 2025/2650. They will now apply from 30 December 2026 to medium-sized and large companies, as well as to micro and small enterprises already covered by the EU Timber Regulation (EUTR), and from 30 June 2027 to all other micro and small enterprises. Neither postponement alters the Regulation’s objective: neither postponement  alters the Regulation’s objective, and both give companies and authorities more time to get traceability, due diligence and enforcement systems up and running.

 

 

What the EUDR requires and why it represents a shift in approach

 

 

The EUDR is based on a simple finding: voluntary commitments to tackle deforestation have failed to halt the loss of forest cover linked to EU imports. The Regulation therefore changes tack. Companies are no longer asked to make commitments; they are required to provide proof.

 

Two requirements apply to every relevant product placed on the EU market or exported from the EU.

 

Deforestation-free. The product must not have been produced on land subject to deforestation after 31 December 2020 and, in the case of wood, must have been harvested without inducing forest degradation after that date.

 

Legality. The product must have been produced in accordance with the relevant legislation of the country of production, covering in particular land use rights, environmental protection, labour rights, tax and anti-corruption rules.

 

The main difficulty is rarely obtaining a general statement from a supplier. It lies in linking each batch to a sufficiently precise origin and to a body of verifiable evidence. Geolocation data may be incomplete, held by several intermediaries or recorded in incompatible formats. Evidence of legality is often even more fragmented: land titles, operating permits, environmental permits, labour records and tax documents are rarely held in one place, or at the same tier of the supply chain.

 

Consider a coffee importer sourcing through an international trading house, which itself buys from several cooperatives. The importer holds sustainability certificates and knows the country, and sometimes the region, of production. However, it cannot yet link each batch to the plots of origin, nor verify that land tenure and administrative documents actually cover every producer associated with that batch. Collecting more documents will not solve this on its own. The link between product, plot, producer and supporting evidence has to be maintained throughout aggregation and processing.

 

 

Who the Regulation applies to

 

 

The EUDR applies to three categories of company along the value chain:

• operators, meaning companies that place relevant products on the EU or export them, including importers;
• downstream operators, meaning companies that place on the market or export products made from relevant products already covered by a due diligence statement, such as manufacturers incorporating a commodity declared further upstream;
• traders, meaning companies that make relevant products available on the market without being the first to place them there.

 

Scope is determined by the product, not by whether a company imports. A manufacturer or retailer can therefore be in scope without ever importing a relevant commodity directly.

 

The furniture sector shows how this works. A retailer may buy finished furniture from European manufacturers without importing any wood itself. It is nonetheless in scope if the products it sells fall under the customs (HS) codes listed in Annex I to the Regulation. Depending on its exact position in the chain, it will need to obtain and retain the information and reference numbers passed on by upstream operators, check which of its products are covered, and maintain traceability between its own product codes and the corresponding due diligence information.

 

Timeline: where implementation stands

 

The table below sets out the timeline as amended by Regulation (EU) 2025/2650, adopted on 19 December 2025.

 

Milestone	Date
Adoption of the Regulation	31 May 2023
Originally scheduled date of application	30 December 2024
First postponement adopted	17 December 2024
Adoption of amending Regulation (EU) 2025/2650	19 December 2025
Publication of the Commission’s review report	4 May 2026
Application to medium-sized and large companies, and to micro and small enterprises already covered by the EU Timber Regulation (EUTR)	30 December 2026
Application to all other micro and small enterprises	30 June 2027

 

The review required under the December 2025 amendment was completed on 4 May 2026, when the European Commission published revised guidance and an updated set of FAQs.

 

Whatever the outcome of the review, one point is worth bearing in mind: the additional time does not change what must ultimately be demonstrated. It is a preparation period, not a relaxation of the core requirements.

 

The simplifications adopted in December 2025

 

 

The negotiations launched in 2025 led to amending Regulation (EU) 2025/2650, published in the Official Journal of the European Union on 23 December 2025. The revision keeps primary responsibility with the operators that first place relevant products on the market or export them, while removing some duplicative formalities further down the chain.

 

Where products are already covered upstream by a due diligence statement or a simplified declaration, downstream operators and traders are no longer automatically required to repeat the entire procedure. They must nevertheless that information is passed along the chain, retain the relevant reference numbers, respond to requests from the competent authorities, and refrain from placing or making available on the market any product where they have information suggesting a risk of non-compliance.

 

A specific regime also applies to micro and small primary operators established in a country classified as low risk. They may submit a one-off simplified declaration. Under certain conditions, the postal address of the plot of land or establishment may be given instead of precise geolocation coordinates, as long as it allows the location to be clearly identified.

 

These simplifications mainly concern administrative procedures and the flow of information. They remove neither the deforestation-free requirement nor the requirement to comply with the relevant legislation of the country of production.

 

 

Due diligence: what the procedure involves in practice

 

 

The Regulation breaks due diligence down into three steps.

 

Information collection. This requires precise identification of the relevant products, geolocation of the plots of land where they were produced, and documentation of the supply chain back to its origin.

 

Risk assessment. This combines the country-level risk classification with an assessment specific to each supplier and supply chain.

 

Risk mitigation. Depending on the level of risk identified, the company implements corrective measures, excludes certain sources of supply or strengthens its supplier checks.

 

The step most often underestimated is information collection and, above all, initial data validation. Companies sometimes approach the EUDR as a supplier risk assessment exercise, yet that assessment can only be robust if products, batches, suppliers, countries of production and plots have first been linked within a consistent data model.

 

Difficulties typically arise with the mixing of batches, processing and changes in product identifiers between the systems of the producer, trading house, importer and manufacturer. An single set of geographic coordinates, or a supplier declaration not linked to the relevant batch, does not amount to usable traceability. Before choosing a tool or formalising a risk matrix, a company therefore needs to define its unit of traceability, the identifiers it will use, the rules for reconciling data, and the controls that prevent undocumented volumes from entering a compliant batch.

 

 

Preparing by level of exposure

 

Not all companies within the scope of the EUDR start from the same point. Three profiles emerge.

 

 

Highly exposed companies

 

 

This group includes direct importers, manufacturers processing the relevant commodities, and international brands active in these supply chains. For them, the priority is full supply chain mapping, the collection of geolocation data, and the organising compliance evidence within existing reporting systems.

 

A thorough mapping exercise can bring unexpected dependencies to light. A food brand might, for example, discover that several of its direct suppliers were sourcing from the same intermediary, concentrating risk in a single area exposed to deforestation. Value chain mapping then gives the company a basis for diversifying and diversifying and de-risking its supply, while preparing for the EUDR’s due diligence requirements.

 

 

Indirectly affected companies

 

 

This group includes retailers, processors and brands that do not import directly but whose suppliers handle one of the relevant commodities. The task is to identify at-risk commodities in their own supply chain, assess critical suppliers, and introduce appropriate contractual requirements. The link with the Corporate Sustainability Reporting Directive (CSRD) is particularly relevant here, as both pieces of legislation push companies towards greater visibility of impacts across their value chains.

 

 

Companies with low exposure

 

 

For these companies, the priority is to monitor regulatory developments, map indirect dependencies, and gradually prepare data collection systems. There is no urgency, but the work should not be put off.

 

 

Compliance goes beyond paperwork

 

 

Meeting EUDR requirements is not just a matter of producing supporting documents. It usually involves structuring product data more broadly, carrying out a partial or full life cycle assessment (LCA) to quantify certain impacts, strengthening value chain traceability, and aligning with CSRD reporting requirements.

 

Life cycle assessment and EUDR due diligence serve different purposes. An LCA evaluates a range of potential environmental impacts across the entire life cycle of a product, drawing on physical flow data and impact assessment models. The EUDR, by contrast, requires companies to demonstrate, for regulatory purposes, the actual origin of the relevant commodities, the geolocation of plots, the absence of deforestation after the cut-off date, and compliance with the legislation of the country of production.

An LCA can contribute directly to EUDR preparation when it helps establish product’s bill of materials, identify the relevant materials, quantify flows, pinpoint processing stages and show where land use drives the results. It can also help compare sourcing scenarios or assess the environmental consequences of a material substitution.

 

An LCA cannot, however, be used to demonstrate EUDR compliance. Country- or sector-average data, however robust from an environmental standpoint, cannot replace traceability information and evidence linked to the plots and batches in question. The two approaches are therefore complementary: LCA assesses impacts and informs eco-design choices, while due diligence establishes the compliance of a specific supply chain.

 

 

What the EUDR reveals about value chain management

 

 

The Regulation is part of a broader shift. Environmental commitments must now be demonstrated, not merely declared. Product data is becoming strategic infrastructure rather than communications material. And carbon-only approaches are reaching their limits when faced with issues such as deforestation, which bear directly on biodiversity and land use.

 

Deforestation illustrates this clearly. It generates significant greenhouse gas emissions, but its consequences extend well beyond them. It destroys or fragments habitats, degrades soils, disrupt water cycles, and drives a decline in species diversity.

 

Carbon and biodiversity approaches also rely on different indicators and scales of analysis. An emissions figure can be estimated from a quantity of material and an average emission factor, whereas deforestation risk depends heavily on where production takes place and on actual land use change. Two sources of supply with a comparable average carbon footprint can therefore have very different risk profiles, depending on the plots, ecosystems and agricultural practices involved.

 

EUDR compliance can thus serve as a starting point for a broader analysis of biodiversity-related impacts and dependencies. The geolocation data collected for the Regulation can be cross-referenced with information on protected areas, rare or threatened ecosystems, water stress or habitat condition. This goes beyond what the Regulation strictly requires, but it helps connect climate, biodiversity and sustainable procurement strategies more effectively.

Mathilde Verrier, LCA and eco-design consultant.