EUDR - EU Regulation on Deforestation-Free Products

The EU Regulation on deforestation-free products (EUDR) was originally due to apply from 30 December 2024 for large companies, with a deferred start date of June 2025 for micro and small enterprises. Following an initial postponement approved in November 2024, discussions held in 2025 led to a proposed application date of 30 December 2025 for medium and large companies, accompanied by a six-month grace period, and 30 December 2026 for micro-enterprises and SMEs. Several simplifications have also been introduced to make the system more practical and effective.

 

Context and purpose of the regulation

 

According to a 2017 WWF report, the European Union was responsible for 16% of global deforestation linked to international trade, making it the world’s second-largest importer of deforestation-associated products after China. In response, the EU strengthened its efforts to curb imported deforestation.

 

This ambition took shape with the adoption of the Regulation on Deforestation-Free Products (EUDR), one of the flagship initiatives of the European Green Deal. The text was adopted by the European Parliament in April 2023 (552 votes in favour, 44 against and 43 abstentions) and published in the Official Journal of the European Union in June 2023.

 

The regulation aims to prevent the placing on the EU market, or the export from the EU, of products whose production is illegal or linked to deforestation occurring after 31 December 2020. It pursues three core objectives: protecting forests, ensuring the legality and sustainability of supply chains, and aligning EU action with its international commitments (Paris Agreement, Sustainable Development Goals, EU Biodiversity Strategy for 2030).

 

Successive postponements and evolving obligations

 

After the initial adjustments confirmed in 2024, the year 2025 saw renewed debate on the implementation timeline. In September 2025, the European Commissioner for the Environment, Jessika Roswall, raised the possibility of a further one-year delay due to the risk of overloading the TRACES traceability system, as reported by Reuters.

 

This prospect prompted immediate reactions. In early October 2025, a coalition of companies from the cocoa, timber, rubber, dairy and agri-food sectors sent an open letter to the European Commission opposing any additional postponement. They emphasised the investments already made to comply with the regulation and warned of heightened regulatory uncertainty, increased costs and potential impacts on competitiveness.

 

At the same time, ahead of COP 30, investors representing approximately USD 3 trillion in assets urged governments to end deforestation by 2030, underscoring the need for a stable and predictable regulatory framework.

Sources: ESG POST and Reuters

 

On 21 October 2025, the European Commission presented a targeted amendment designed to stabilise the timeline while adjusting the obligations:

• the additional one-year delay would apply only to micro and small enterprises
• medium and large companies would remain bound by the 30 December 2025 deadline
• a six-month grace period would be introduced for inspections and enforcement

 

This phased approach is intended to preserve the credibility of the regulation while recognising the technical and organisational constraints faced by operators.

 

Objectives of the EU Regulation on Deforestation-Free Products

 

The regulation pursues three fundamental objectives:

• protecting forests and preserving global forest ecosystems
• ensuring legality and sustainability across supply chains
• complying with World Trade Organization rules

 

Its specific aims are to:

• reduce the risk of importing or exporting products linked to deforestation
• stimulate demand for commodities that are not associated with deforestation
• reshape supply chains by improving transparency

 

Commodities covered by the EUDR

 

The regulation applies to seven key commodities and their derived products: coffee, cocoa, soya, beef, wood, palm oil and rubber.

 

Companies must demonstrate that their products:

 

• •have not caused deforestation after 31 December 2020
• comply with environmental, land-use, social and fiscal laws in the country of production
• are accompanied by a due diligence statement recorded in the TRACES system

 

The production date corresponds to the date of harvest. For animals, it covers their entire lifespan, including slaughter. All data must be retained for five years.

 

Risk assessment

 

To be placed on the market or exported, products must:

• be free from deforestation
• comply with all relevant legislation in the country of origin
• be covered by a due diligence statement including plot-level geolocation, risk assessment and mitigation measures

 

Preparing for EUDR implementation

 

Since 2023, a platform bringing together Member States and stakeholders has supported the implementation of the regulation. Two expert groups have been established: one dedicated to smallholders, and one focusing on traceability. Their work informs the official FAQ and the guidance documents published by the European Commission.

 

Tools made available include:

• comprehensive guidance documents
• sector-specific guidelines published progressively since late 2024
• the TRACES information system and its user guide
• explanatory videos
• training sessions

 

The European Observatory on Deforestation and Forest Degradation

 

Launched in December 2023, the European Observatory is now fully operational. It provides maps and datasets that support risk assessment, including:

• satellite monitoring of global forest cover
• reference maps and change maps (2016 to 2022)
• information on trade flows for the commodities covered
• near-real-time landscape analysis tools

 

Observatory and data
 

Deadlines and business preparedness

 

The risk classification of countries and regions, initially expected by late 2024, was ultimately released as an initial list in May 2025.

 

In France, a competent authority was designated at the end of 2023 and its mandate continues to be refined.

 

Given the revised timeline, the first inspections are expected from 2026. Companies should already be:

• mapping their suppliers
• gathering traceability data
• verifying legal compliance within their supply chains
• preparing their TRACES submissions

 

 

Preparing for EUDR compliance now

 

The EUDR represents a significant shift for supply chains: proving the absence of post-2020 deforestation, ensuring legal compliance in the country of origin and establishing a robust, traceable due diligence system. Despite the postponements, the core requirements remain unchanged, and the first inspections are expected from 2026.

 

Companies therefore stand to benefit from strengthening their data, procedures and traceability architecture now. At EVEA, the R&D team is actively working on biodiversity-related issues and on assessing the impacts associated with the commodities concerned, in order to better understand ecosystem pressures and support implementation of the regulation.

 

Beyond compliance, the EUDR forms part of a wider global effort to protect forests, enhance transparency and align economic activity with the EU’s climate and biodiversity commitments.

 

Content overseen by Mathide Verrier, LCA and eco-design consultant