EU Deforestation Regulation (EUDR)

Restricts import and sale of products linked to deforestation, requiring strict supply chain due diligence.

The EU Deforestation Regulation (EUDR), published as Regulation (EU) 2023/1115 and revised by Regulation (EU) 2025/2650 in December 2025, is the EU's most ambitious attempt to break the link between European consumption and global deforestation. It prohibits the placing on or export from the EU market of seven key commodities -- cattle, cocoa, coffee, oil palm, rubber, soya, and wood -- and their derived products unless they are verified as deforestation-free and produced in compliance with local laws. The cut-off date is 31 December 2020: any product linked to land deforested after that date cannot enter the EU market.

The regulation applies to all operators and traders regardless of company size or country of origin. If you place regulated commodities or derived products on the EU market, you must comply. The December 2025 Omnibus revision introduced a new "downstream operator" category for processors further along the supply chain and created simplified obligations for micro and small primary operators sourcing from low-risk countries. Printed products (books, newspapers) were removed from scope entirely.

At the heart of EUDR is an unprecedented geolocation requirement. Operators must collect the precise geographic coordinates of every plot of land where regulated commodities were produced. For plots under 4 hectares, a single point with area size suffices; for larger plots, a full polygon boundary is required. This data must be submitted through the EU Information System alongside a due diligence statement before goods can be placed on the market. There are no exemptions from the geolocation obligation.

The Commission's country benchmarking system classifies producing countries into three risk tiers: low, standard, and high. As of May 2025, 140 countries are classified as low risk (including all EU member states), approximately 50 as standard risk (including Brazil, Indonesia, and Malaysia), and four as high risk (Belarus, Myanmar, North Korea, Russia). The risk tier determines both the depth of due diligence required and the frequency of checks by competent authorities -- 1% for low-risk, 3% for standard, and 9% for high-risk sources.

Following two postponements -- first from December 2024 to December 2025, then to December 2026 under the Omnibus simplification -- large and medium operators must comply by 30 December 2026, with micro and small operators given until 30 June 2027. The Commission was required to deliver a simplification report by 30 April 2026 evaluating administrative burden, particularly on SMEs. Despite the delays, the underlying obligations remain substantively unchanged, and companies are strongly advised to use the remaining time to build traceability systems rather than postpone preparation.

EUDR does not operate in isolation. It replaces the EU Timber Regulation, aligns with the Corporate Sustainability Due Diligence Directive (CSDDD) and CSRD, and complements the EU's broader Green Deal ambitions. A 2028 review may extend its scope to other ecosystems such as wetlands and savannas, and potentially bring financial institutions within its reach.

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