Ensure compliance and market access
The EU Deforestation Regulation (EUDR) was adopted on 29 June 2023. It aims to reduce the EU’s impact on deforestation and biodiversity loss by setting import and export requirements for products linked to these issues. This regulation highlights the EU’s commitment to environmentalism, similar to the Carbon Border Adjustment Mechanism (CBAM). The EUDR targets products like cattle, wood, cocoa, soy, palm oil, coffee, rubber, and their derivatives. If you import, supply, or export these products within the EU, you will be affected. Implementation is expected by 30 December 2025 for large and medium companies, and 30 June 2026 for small and micro enterprises. Despite a one-year delay, traders should start preparing now due to the extensive due diligence requirements.
What does EUDR mean for businesses?
The EUDR imposes strict due diligence requirements on businesses dealing with certain commodities in the EU market. Products must meet three conditions:
Deforestation-free: products must not come from land deforested or degraded since 31 December 2020.
Legal compliance: products must comply with the relevant laws of the production country and international human rights laws.
Due diligence statement: products must be covered by a due diligence statement.
Your obligations depend on whether you are an “operator” or a “trader,” based on your role in the goods’ movement in or out of the EU.
Operator requirements
An operator is any person or entity that places relevant products on the EU market or exports them from the EU. If based outside the EU, the first person making these products available in the EU is deemed the operator.
A product is considered ‘placed on the EU market’ when it is first made available there. This includes:
Goods produced in the EU for further commercial activities.
Goods imported into free circulation from outside the EU.
Goods released from customs procedures into free circulation in the EU.
Operators using products subject to the EUDR in the EU must comply with requirements for both imported raw materials and final products. For exports, the operator is typically the exporter.
Operators must:
Complete a due diligence exercise and risk assessment for each product.
Submit a due diligence statement to authorities before placing products on the EU market or exporting them.
Not place or export products if they are non-compliant, if a non-negligible risk is identified, or if due diligence has not been performed and submitted.
What the due diligence exercise involves for operators
The due diligence exercise aims to prevent products linked to deforestation from entering or leaving the EU. Operators must gather the following information:
Product details: description and quantity of products.
Origin of products: country of production, geolocation of all plots where commodities were produced, and production date range.
Supplier details: information on businesses or individuals who supplied or received the products.
Verifiable evidence: proof that products are deforestation-free and comply with the production country’s laws.
This information must be retained for five years from the date the products are placed on the market or exported.
Risk-assessing EUDR products
Collecting due diligence information is the first step for businesses. The next step is to conduct a risk assessment to determine product compliance with EUDR. The regulations specify criteria, including the country of production. The EU will use a three-tier system to assess countries:
High risk: high deforestation rates, forest degradation and agricultural expansion.
Low risk: countries where there is sufficient assurances that high deforestation rates, forest degradation and agricultural expansion are not occurring.
Standard risk: countries not classified as high or low risk.
The EU Parliament proposed an additional tier for “no risk” goods where a due diligence statement may not be required before placing goods on the EU market or exporting them. This proposal was not accepted for implementation in December 2025, but may be considered in future reviews.
The due diligence statement
Operators placing EUDR products on the EU market or exporting them must submit a due diligence statement on the EUDR Information System before doing so. The statement must include:
Operator details (economic operators registration and identification (EORI), address).
Harmonised system (HS) code and product description.
Country of production and geolocation of all plots where commodities were produced. For cattle-related products, this includes all establishments where cattle were kept.
Reference number of an existing due diligence statement, if applicable.
Confirmation text: ‘By submitting this due diligence statement the operator confirms that due diligence in accordance with Regulation (EU) 2023/1115 was carried out and that no or only a negligible risk was found that the relevant products do not comply with Article 3, point (a) or (b), of that Regulation.’
Appropriate signature.
Operators can appoint an authorised representative to submit the statement, but they remain responsible for product compliance with EUDR. This also applies to traders.
Trader requirements
Traders are those in the supply chain, other than operators, who make relevant products available on the EU market. Unlike operators, traders do not place products on the market but make them available for distribution, consumption or use. This means the products have already been imported into the EU or produced within the EU.
For example, an EU wholesaler (SME operator) imports cocoa powder from a non-EU producer and sells it to an EU retailer (non-SME trader). The wholesaler is the operator, while the retailer, who resells the cocoa powder, is the trader. The retailer can refer to the wholesaler’s due diligence statement but is responsible for compliance.
Non-SME traders have the same obligations as operators. SME traders must have the reference number of the due diligence statement from the relevant operator or trader to make products available on the market.
Key actions businesses can take today
- Identify affected products: determine if the products you import, place, or make available on the EU market, or export, are subject to EUDR requirements.
- Assess existing data: review the data you already have for the due diligence exercise and identify any gaps.
- Plan data collection: create a roadmap to obtain the missing data, allowing ample time for risk assessments.
- Conduct risk assessments: perform risk assessments for each product.
- Prepare due diligence statements: start preparing due diligence statements for each product, assigning roles and responsibilities for submission.
We are here to help you
Navigating the complexities of the EUDR can be challenging, but our team of experts is here to assist you every step of the way. We have a deep understanding of the EUDR and its implications for businesses across various industries. Our full suite of services is designed to help you achieve and maintain compliance, including establishing due diligence frameworks, providing training and education, and offering regulatory updates. We understand that every business is unique. That’s why we offer customised solutions that align with your specific operational needs and business goals. To discuss this further, contact us today.
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