EUDR – European Deforestation Regulation

Even following the European Commission’s review of potential simplifications (update as of May 4, 2026), the regulation’s timeline remains largely unchanged: For large and medium-sized operators as well as traders, the regulation applies starting December 30, 2026. This also applies to micro and small enterprises that are already subject to the EU Timber Regulation (EUTR). For micro and small enterprises (operators) that have not yet fallen within the scope of the EUTR, an extended transition period until June 30, 2027, will be granted.

The initial focus of the EUDR is on coffee, cocoa, cattle, palm oil, soya, rubber and wood, as well as a large number of derived products. The requirements apply, for example, to leather goods, tires, seals, chocolate, roasted coffee, glycerin, soybean oil, plywood, and furniture. Books, newspapers, and other printed materials have been excluded from the scope of the EUDR.

Due diligence obligations under the EUDR include, in particular, the structured collection of relevant information, including detailed data on the geolocation of production areas, the conduct of a robust risk assessment and, if necessary, the implementation of appropriate risk mitigation measures. As part of the risk assessment, in addition to assessing the risk of deforestation and forest degradation, , further aspects must also be addressed – such as compliance with local legal requirements, consideration of the rights of indigenous peoples, and risks arising from mixing with non-compliant relevant products. Based on the collection of information and the risk assessment, companies placing products on the EU market for the first time are required to issue a due diligence statement and assume responsibility for the compliance of their supply chains.

At the same time, the current simplifications provide targeted relief for micro or small primary producers (MSPO): These entities only need to submit a one-time simplified due diligence statement, which must be updated only in the event of significant changes. Additionally, a clearly identifiable postal address may be provided instead of detailed geolocation data, when it corresponds to the geographic location of the plots of land or establishment concerned.

Non-SME operators and non-SME traders are subject to more extensive due diligence obligations as well as higher requirements for transparency and governance: The measures implemented to fulfil due diligence obligations must be reviewed regularly – at least annually – and reported publicly in an appropriate form.

Companies will now have to use the transition period to analyze their own procurement and product portfolios and identify any gaps. As with the German Supply Chain Due Diligence Act (LkSG) and the upcoming Corporate Sustainability Due Diligence Directive (CSDDD), transparency and data availability are key to fulfilling the requirements. Creating transparency not only enables companies to achieve compliance with the EUDR but also empowers them to identify and proactively address risks and opportunities in their own supply chain.

For example, the CSDDD addresses comprehensive human rights and environmental due diligence obligations across a company’s own business operations, at subsidiaries, and throughout large parts of the value chain, while the EU Forced Labour Regulation (EUFLR) prohibits the placing on the market of products manufactured wholly or partly through forced labor.

By strategically integrating these regulatory requirements, companies can establish a uniform, holistic due diligence system. In some cases, targeted adjustments to local requirements must be made.

We are happy to support you in systematically leveraging synergies, taking local particularities into account, avoiding double effort, and further developing existing compliance structures in an efficient and sustainable manner.

Together, we identify opportunities for optimization, reduce complexity, and develop pragmatic solutions for governance and ESG data management, individually tailored to your needs.

If companies are unable to fulfil the required due diligence obligations, the commodities and products covered by the regulation may not be placed on the market. In addition to reputational risks, violations of the regulation also expose companies to massive financial risks, through:

• Coercive fines and penalties
• Temporary bans on the placing on the market, trade or export of relevant commodities or products
• Temporary exclusion from public procurement
• Reimbursement of the authorities’ financial expenses