EUDR Explained: Key Requirements, Deadlines, and Compliance Guide for Companies

Content Overview

1. EUDR explained
2. Timeline
3. Affected Companies
4. Affected Products
5. Implementation Strategy
6. Sanctions
7. Background Information

What is the EUDR? A brief overview

The EUDR introduces extensive due diligence obligations. Companies must ensure their products are deforestation-free. The focus is on transparency and traceability throughout the supply chain — businesses must be able to track a product’s journey from origin to market without gaps.

The EUDR requires companies to collect detailed data. As Klaus Wiesen, our supply chain expert, explains: “Given the complexity, it’s clear that software is a must for implementation. That already applies to the LkSG, but even more so for the EUDR — a pragmatic approach is nearly impossible without digital tools.”

When will the EUDR come into force?

The EUDR applies to large and medium-sized companies starting December 30, 2025. Small companies have an additional six months to comply.

Which products are covered by the EUDR?

The regulation applies to the following commodities and their derived products:

• Wood
• Palm oil
• Coffee
• Cocoa
• Cattle
• Soy
• Rubber

There are no thresholds or volume limits. The list of covered commodities is expected to expand over time.

Exemptions:

• 100% recycled materials
• Packaging materials solely used for support, protection, or transportation
• User manuals
• Bamboo products
• Products manufactured before the EUDR’s reference date (June 29, 2023), except for wood products

What conditions must products fulfill under the EUDR?

Starting with the implementation phase: Import, trade and export of the above-mentioned raw materials and their derived products on the EU internal market are only permitted, if these three conditions are met:

• Deforestation-free: The products were manufactured without converting natural forest into agricultural land or tree plantations after 31.12.2020. This also applies if deforestation was considered legal in the country of origin!
• Production in accordance with the relevant rights of the country of origin: This concerns both environmental protection and human rights. Species protection measures, anti-corruption measures, labor rights, the UN Declaration on the Rights of Indigenous Peoples, trade law, etc. have been complied with.
• Due diligence declaration available: A risk assessment has been carried out for the product, the due diligence obligations have been complied with and there is no or only a negligible risk of deforestation.

How can companies prepare? Practical steps for EUDR implementation

Step 1: Determine your EUDR market tole

Companies must classify themselves as operators or traders — and as SMEs or non-SMEs according to EUDR criteria (note: these differ from general EU definitions).

Key differences:

• Operators must conduct risk assessments, mitigate risks, and submit a due diligence statement via the EU’s “TRACES” system.
• Traders may rely on the due diligence statement, but non-SME traders must verify risk assessments through spot checks.
• SMEs benefit from a simplified set of obligations, including reduced reporting requirements.

Step 2: Collect EUDR data

Gather detailed information about your products and raw materials — including descriptions, volumes, suppliers, and countries of origin.

The EUDR requires geo-location data for every plot where relevant commodities are produced, including production dates — retroactively from December 31, 2020.

Ensure proof that all legal rights are respected in the country of origin.

Step 3: Conduct risk assessment

Evaluate the deforestation risk for any new product or commodity.

Factors include:

• Country of origin
• Deforestation trends
• Political and social conditions
• Supply chain complexity

The EU will provide a benchmarking system categorizing countries by risk level. Only products with no or negligible risk may enter the EU market.

Step 4: Mitigate risks

If risks are identified, work with suppliers to reduce them. Develop new codes of conduct, strategies, and control measures. Verify compliance via supplier audits or documentation

Step 5: Document and report

Companies must maintain detailed records and submit reports.

For every batch, a due diligence statement or EUDR compliance confirmation must be included — customs will verify compliance based on risk assessments.

Except for SMEs, companies must also publicly report on risk assessments, due diligence processes, and mitigation measures. If your company is subject to the CSRD, you can integrate EUDR reporting into your sustainability report.

Background on the EUDR

In the past 30 years, global deforestation has wiped out an area larger than the EU. Forest loss accelerates climate change and biodiversity loss.

The EUDR follows the EU Timber Regulation (EUTR) from 2013, which was criticized for weak enforcement. As part of the European Green Deal, the EUDR strengthens these efforts.

From 2025 onwards, it will be prohibited to place, make available, or export certain products in the EU market if they are linked to deforestation or forest degradation since January 2021 — regardless of whether the forest is in Germany, Romania, or Brazil.