EUDR update: objective, obligations and new timetable
Due diligence

EUDR update: objective, obligations and new timetable

With the EU Deforestation Regulation (EUDR), the EU is taking action against deforestation and forest degradation worldwide. It must be complied with from December 30, 2026.

EUDR: Introduction

Regulation (EU) 2023/1115 is one of the most important measures for the global protection of forests. In addition to wood itself, the regulation also focuses on other products for the extraction of which forests are constantly being cleared.

Originally, the EUDR of May 31, 2023 was to be applied as early as December 30, 2024 – but the start was initially postponed by one year, and then by another year in December 2025. In addition, further changes were implemented with Regulation (EU) 2025/2650

The provisions of the EUDR will now apply to large market players from December 30, 2026. Micro and small enterprises will not have to comply with the EUDR until June 30, 2027. 

In the following chapters, let's take a look at the current status of the EU Deforestation Regulation.

The goal: Protecting forests

With the deforestation regulation, the EU wants to counteract the global loss of forest areas. The explanatory memorandum includes the United Nations' estimate that around 10 percent of the world's forests have already been lost between 1990 and 2020. 

The EUDR therefore contains provisions for making goods that contain or have been produced using relevant raw materials available in the EU market and for exporting them from the EU. 

The authorities of the EU member states are responsible for compliance with the regulation in primary production (agriculture and forestry).

EUDR: Who is affected?

According to Annex I of the Regulation, producers, market players, and traders for the following raw materials and the products made from them are subject to requirements in their global trade with the EU (export and import):

  • Cocoa
  • Coffee
  • Rubber
  • Oil palm
  • Soy
  • Cattle

Listed products made from these include palm oil derivatives, animal feed, soft rubber goods, leather, and furniture.

Companies in the EU that import, export, manufacture, process, and/or trade in these materials and products are subject to the regulation. The scope of the due diligence obligations depends largely on where in the supply chain the company is located.

Note: Wooden or cardboard packaging that is not sold as a stand-alone product but encloses other products is not covered by the EUDR. Books, newspapers, and printed matter have also been excluded from the scope of the EUDR. Further information can be found in the FAQs and Guidance Document for Regulation (EU) 2023/1115 of the EU Commission.

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EUDR: What needs to be done?

In future, companies making products subject to the EUDR available on the EU market for the first time will have to provide a due diligence declaration to prove that the relevant raw materials were obtained without deforestation. This must be submitted in accordance with Annex II of the regulation and archived for five years.

Products are considered deforestation-free if they do not originate from an area deforested after December 31, 2020, or have led to deforestation after this date. In addition, the relevant legislation of the country of production must be complied with. This includes laws on nature conservation as well as workers' rights, human rights, and the protection of indigenous population groups – see Article 2 (40).

The new group of "small and micro primary producers" introduced in December 2025 only have to submit a one-off and simplified declaration in accordance with EUDR Annex III instead of a due diligence declaration. In this simplified declaration, a business address is sufficient as localization, for example. They then receive a one-off identification number that they can attach to their products that are subject to the EUDR.

As first distributors in the EU, market players either use this identification number or must obtain information on the relevant raw materials and products, including HS codes, quantity, country of production, and geolocation of the raw material production sites. They must then research whether the raw materials and products have been obtained deforestation-free in accordance with the criteria set out in Article 10 and carry out a risk assessment. If a risk is identified, risk mitigation measures must be initiated before the goods are allowed to enter the EU market. In the subsequent due diligence declaration, you confirm that no risk or only a negligible risk has been identified.

On May 22, 2025, the EU Commission published a list of countries by risk status for the European Deforestation Regulation (EUDR). This classified all EU member states and over a hundred other countries as low risk, for which a simplified due diligence obligation applies. The higher the risk in the producing country, the higher the inspection rates. Only Belarus, Myanmar, North Korea, and Russia were classified as high-risk countries.

The EU Commission's FAQs and the Guidance for Regulation (EU) 2023/1115 are updated regularly and provide further assistance (see relevant links in the above chapter).

Note: Only the first downstream market player or trader must collect the reference numbers of the due diligence declarations from the manufacturer or importer or the identification numbers of the small or micro primary producers. Further downstream market participants and traders in the supply chain are no longer obliged to do so since the simplifications adopted at the end of 2025.

EU information system "Due Diligence Register"

In order to submit a due diligence declaration, companies must apply for access to the deforestation due diligence register. 

The following information is required to submit a due diligence declaration:

  • Activity: Import, export, or domestic production
  • Place of trade
  • Product type with HS code (for example "soybeans", all goods are available with HS code in the selection menu)
  • Quantity/mass/volume
  • Geolocation data of the place of origin of the goods

Go to the EU Information System of the Deforestation Regulation

Tip: Check in good time whether you fall under the EUDR regulations. If this is the case, you should set up your internal company organization accordingly.