EU Deforestation Regulation

The EU Deforestation Regulation (EUDR) is Regulation (EU) 2023/1115 on the making available on the Union market of certain commodities and products associated with deforestation and forest degradation. It replaces the earlier EU Timber Regulation (EUTR) and covers seven commodities – cattle, cocoa, coffee, oil palm, rubber, soy and wood – along with a long list of derived products such as leather, chocolate, furniture, paper, tyres and charcoal, delimited by CN codes in Annex I. Anyone who places such products on the EU market, makes them available or exports them from the EU may only do so if they are deforestation-free, were produced in accordance with the legislation of the country of production, and are covered by a due diligence statement. The decisive cut-off date is 31 December 2020: land deforested after that date – or, in the case of wood, degraded – is out of scope for compliant sourcing.

The obligations rest on a three-step due diligence system. First, information gathering: alongside trade data, quantity, supplier and country of production, operators must hold geolocation data for every plot of land on which the commodities were produced – polygons for plots larger than four hectares, point coordinates with at least six decimal places for smaller ones, and for cattle the establishments where the animals were kept. Second, risk assessment, which weighs factors such as the Commission's country benchmarking (low, standard or high risk), the prevalence of deforestation in the region, the complexity of the supply chain and the rights of indigenous peoples. Third, risk mitigation through additional evidence, independent verification, satellite analysis or supplier audits until no more than a negligible risk remains. For commodities from low-risk countries, simplified due diligence without risk assessment and mitigation is sufficient. The due diligence statement is filed electronically in the EU information system (TRACES), and its reference number travels down the supply chain.

The EUDR timeline has been postponed several times and remains politically contested. The regulation was originally due to apply from 30 December 2024; a first amendment pushed this back by one year to 30 December 2025 for large and medium-sized companies and 30 June 2026 for micro and small enterprises. At the end of 2025 the Council and Parliament agreed a further one-year delay together with simplifications, including an annual rather than per-consignment statement and relief for downstream operators. Companies should therefore always check the currently applicable text of the regulation and the Commission's guidance rather than rely on dates announced at some earlier point. In Germany the competent authority is the Federal Office for Agriculture and Food (BLE); infringements can be sanctioned with fines of at least four percent of Union turnover, confiscation of the goods and of the revenue gained, and exclusion from public procurement. Substantively, the EUDR dovetails with the German Supply Chain Act (LkSG), the CSDDD and reporting under ESRS E4 on biodiversity and ecosystems.