1st July 2023

Updated: 27th November 2025

Introduction

As global pressure to address climate change and deforestation intensifies, the European Union is rolling out one of the most significant sustainability regulations to date: the EU Regulation on Deforestation-Free Products (EUDR).

Originally intended to apply at the end of 2024, the EUDR was already granted a one-year postponement. In a further update, on 26 November, Members of the European Parliament approved an additional one-year delay. This moves the main compliance deadlines to 30 December 2026 for large operators and traders, and 30 June 2027 for micro and small companies. The extension is intended to give businesses and authorities more time to prepare, test the EU-wide due-diligence IT system, and refine geolocation-based traceability processes.

The EUDR will ultimately transform supply chains for key agricultural and forest-based commodities entering or leaving the EU. Companies placing, selling, or exporting in-scope products must prove that they are deforestation-free, legally produced, and fully traceable back to their source.

This updated guide outlines the EUDR’s scope, the new timelines, the due-diligence requirements, and what your business should be doing now.

What Is the EUDR?

The EU Deforestation-Free Products Regulation aims to ensure that certain high-risk commodities placed on the EU market do not contribute to deforestation or forest degradation, anywhere in the world.

Commodities covered under the EUDR

The regulation applies to seven major commodities and their derived products:

  • Cattle
  • Cocoa
  • Coffee
  • Palm Oil
  • Rubber
  • Soy
  • Wood/Timber

This includes hundreds of downstream products such as furniture, chocolate, leather, paper packaging, tyres, plywood, palm-oil derivatives, and more.

Who must comply?

The EUDR applies to:

  • EU producers
  • Importers bringing covered goods into the EU
  • Exporters sending covered goods out of the EU
  • Traders and distributors within the EU

Large and medium-sized operators face the most extensive requirements, while SMEs and micro-enterprises benefit from simplified procedures — though they cannot opt out entirely.

Updated EUDR Compliance Deadlines (2025–2026)

Due to operational challenges and readiness concerns, the EU institutions formally approved a one-year delay.

New entry-into-application dates:

  • 30 December 2025
    Large and medium-sized companies must comply
  • 30 June 2026 (proposed final date for SMEs)
    Micro and small enterprises must comply with simplified obligations

Transitional rules

  • Products placed on the EU market before the above dates are exempt.
  • Products placed on the market during the transition but sold after the deadline must still meet EUDR standards.

Businesses should therefore avoid stocking products that cannot be traced or verified.

Due Diligence Requirements

The EUDR is built around a strict three-step due diligence system, mandatory for operators placing products on the market.

1. Information Collection

Businesses must gather detailed evidence including:

  • Geolocation coordinates of every production plot
  • Proof of legal production under the producer country’s laws
  • Supply chain mapping for all actors involved
  • Date or time range of production
  • Commodity and product type details

A due diligence statement (DDS) must be submitted via the EU Information System before placing or exporting products.

If a business cannot obtain the required data, the product cannot be placed on the EU market.

2. Risk Assessment

Operators must assess whether there is any risk that the product:

  • Originated from land deforested after 31 December 2020
  • Was produced illegally
  • Has incomplete supply chain information
  • Comes from a region or country showing high forest-loss trends

They must document:

  • Data reviewed
  • How risk was evaluated
  • Why the operator believes the risk is low

Certification schemes can help — but cannot replace the risk assessment.

3. Risk Mitigation

If any risk is identified, businesses must take steps such as:

  • Requesting additional documents
  • Conducting independent audits
  • Changing suppliers
  • Increasing supply chain monitoring

Low-risk countries will have an accelerated process, while high-risk countries face stricter obligations.

Traceability Requirements

One of the biggest challenges for businesses is achieving full traceability.

Geolocation rules:

  • Plots under 4 hectares: one coordinate point
  • Plots over 4 hectares: polygon mapping using multiple coordinates

Key expectation:

Every batch must be traceable — no mixing with unknown origin materials.

This applies to:

  • Bulk shipments
  • Composite products
  • Blended cocoa, coffee, or soy
  • Timber and wood pulp
  • Rubber used in tyres or footwear

If geolocation cannot be confirmed, the product cannot be marketed or exported from the EU.

Country Benchmarking

The European Commission is developing a risk classification system for countries or regions:

  • Low risk
  • Standard risk
  • High risk

This will determine:

  • The level of due diligence required
  • The percentage of operators subject to inspections
  • The burden on importers and exporters

Countries will be assessed on factors such as deforestation rates, enforcement, agricultural expansion, and forest degradation.

How Your Business Can Prepare Now

Even with the delayed deadlines, preparation is essential.

1. Map your supply chains immediately

Identify every supplier, plot, and intermediary.

2. Secure geolocation data early

This is the single most challenging requirement for many companies.

3. Upgrade internal compliance systems

Ensure you can store documentation for at least five years.

4. Review contracts with suppliers

Include EUDR-specific obligations and data requirements.

5. Work with certification bodies — but don’t rely solely on them

They assist, but cannot replace due diligence.

6. Train procurement and compliance teams

Everyone handling these commodities must understand EUDR requirements.

Conclusion

The EU Deforestation-Free Products Regulation represents a major shift toward sustainable global supply chains. With new enforcement dates set for 2025 and 2026, businesses now have additional time — but the obligations remain stringent.

By implementing strong due diligence systems, ensuring full traceability, and preparing documentation early, companies can not only achieve compliance but also demonstrate leadership in ethical sourcing and environmental responsibility.

The EUDR is not just a regulatory requirement — it’s an opportunity to future-proof your supply chain and support global efforts to protect the world’s forests.