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EU Deforestation Regulation (EUDR)

ENFORCEMENT TIMELINE

Entered into force June 2023; phased application from December 2026

Enforcement: Entered into force June 2023; phased application from December 2026

Overview

The EU Deforestation Regulation (EUDR, Regulation (EU) 2023/1115) is a supply chain access regulation aimed at curbing global deforestation and forest degradation. It effectively prohibits placing specified commodities on the EU market — or exporting them from the EU — unless companies can rigorously trace and prove, through due diligence, that the products are "deforestation-free" and were produced in compliance with the laws of the country of production.

The regulation rests on four main pillars. First, a due diligence system requiring operators to confirm deforestation-free status through a three-step audit process (information gathering, risk assessment, and risk mitigation), along with mandatory tracking of geolocation (GPS coordinates) and production-date data. Second, a defined scope of covered commodities: seven major commodities — cattle, wood, cocoa, coffee, palm oil, soy, and rubber — along with derived products such as leather goods, paper and cardboard, and chocolate. Third, a market surveillance and enforcement regime built around the TRACES international trade system, requiring advance registration of due diligence statements (DDS), integration with customs procedures, and steep penalties for non-compliance (a minimum of 4% of EU-wide turnover, among other measures). Fourth, an application timeline that has been officially pushed back in stages in response to implementation readiness concerns and pushback from member states. The regulation is also linked to related EU frameworks, including land use and forestry carbon sink management (LULUCF), packaging and value-chain traceability design (ESPR), and supply chain decarbonization and environmental due diligence (CBAM).

Enforcement Timeline

June 9, 2023: The EUDR is published in the Official Journal; it enters into force on June 29.

November 2024: The European Commission proposes a bill to delay application by 12 months, to allow more preparation time.

December 2025: The European Parliament and Council formally agree on the delay and simplification measures.

December 30, 2026: Application deadline for large companies and medium-sized operators (the regulation takes effect).

June 30, 2027: Application begins for micro and small enterprises (SMEs).

Related Regulations / Topics

EUDR Due Diligence Statement (DDS) Submission Process and Value Chain Responsibility Allocation

This card focuses on the practical process of preparing and submitting a Due Diligence Statement (DDS) under the EU Deforestation Regulation (EUDR: Regulation (EU) 2023/1115), and on how responsibility is allocated among operators across the value chain. Under EUDR, operators placing covered commodities (cattle, cocoa, coffee, palm oil, rubber, soy, and wood) and their derived products on the EU market, or exporting them from the EU, are legally required to submit and register a DDS through the European Commission's information system (TRACES NT / the EUDR Information System) before trading or shipping the goods. By submitting a DDS, an operator ultimately takes on legal responsibility for confirming that the relevant product in its value chain is deforestation-free and was produced in compliance with the laws of the country of production. The regulation sets out concrete compliance requirements, including a system for downstream operators and SMEs to reference an upstream DDS reference number under simplified arrangements, and a five-year document retention obligation.

EUDR Risk Assessment Requirements and Risk Mitigation Implementation Practice

This card focuses on the specific criteria and operational practice for 'risk assessment' and 'risk mitigation' under Articles 9 and 10 of the EU Deforestation Regulation (EUDR: Regulation (EU) 2023/1115). In the risk assessment step — the second step of due diligence under EUDR — operators must rigorously assess, based on the geolocation and sourcing data they have collected, whether there is no or only a negligible risk that the relevant product is linked to deforestation, or that it was produced in violation of the laws of the country of production (covering matters such as land use rights, human rights, labor rights, tax law, and anti-corruption law). Where a risk is found not to be negligible, the operator must carry out risk mitigation measures — the third step — such as gathering additional data, commissioning independent third-party audits, or conducting on-the-ground investigations of suppliers, and is prohibited from submitting a DDS or placing the product on the market until the risk has been reduced to a negligible level.

EUDR Geolocation (GPS/Polygon) Data Collection Standards and EU TRACES NT System Registration Requirements

This card focuses on the geolocation data collection and verification requirements under Article 9 of the EU Deforestation Regulation (EUDR: Regulation (EU) 2023/1115), and on the practice of registering that data with the EU Information System (TRACES NT). EUDR legally requires the collection and traceability of precise geolocation data for every plot of land where the raw materials in a covered product were produced. For relatively small plots of four hectares or less, a single geographic coordinate point (to at least six decimal places) is permitted; for plots larger than four hectares, operators must collect polygon data precisely delineating the boundary of the plot. Operators must register and submit the geolocation data they collect, together with production date data, to the EUDR digital portal built on the European Commission's TRACES NT (Trade Control and Expert System New Technologies) platform.

EUDR Country and Regional Risk Benchmarking System and Simplified Due Diligence Requirements

This card focuses on the structure of the Country Benchmarking System under Article 29 of the EU Deforestation Regulation (EUDR: Regulation (EU) 2023/1115), its risk classification criteria, and the associated Member State sampling inspection rates and simplified due diligence requirements. Based on objective and transparent scientific assessment, the European Commission classifies and publishes countries or specific regions worldwide into one of three risk categories: Low Risk, Standard Risk, or High Risk. Assessment factors include the rate of deforestation and forest degradation, trends in agricultural expansion, UN and EU restrictive measures, the protection of indigenous peoples' rights, and compliance with the UN Framework Convention on Climate Change. Where a product's country of production is designated Low Risk, operators may apply Simplified Due Diligence, which exempts them from the second and third steps of due diligence — risk assessment and risk mitigation.

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Business Impact

Manufacturing and logistics companies that export wood-based packaging materials or pallets to the EU, or distribute them within the EU, will need to work with suppliers to collect GPS location data (plot-level) identifying the forest where the wood was harvested, and establish a process for submitting this data to the EU's TRACES system. Incomplete location data leads directly to customs holds.

Related Content

Official Sources & Reference Links