EUDR – European Deforestation Regulation

Your expert for questions

Andreas Feiner ist Partner, Sustainability bei PwC Deutschland

Andreas Feiner
Partner, Sustainability Services at PwC Germany
Phone: +49 171 8404662
Email

How to minimise the risk of contributing to global deforestation

Are you familiar with the European Deforestation Regulation (EUDR)? Do you know whether and how the regulation applies to you?

The EU regulation on deforestation-free supply chains, which went into effect at the end of June 2023, requires companies to fulfil due diligence obligations to reduce global deforestation. The deciding factor is the “deforestation status” of production areas as of December 30, 2020, which must be verified along the supply chain.

“In the case of non-compliance with the EUDR, companies could face fines exceeding four percent of their annual turnover.”

Andreas Feiner,Partner, Sustainability Services at PwC Germany

Understanding the extent of their products’ implications under the EUDR is crucial for companies, whether as operators or traders. This knowledge allows companies to navigate the market and trade relevant commodities such as coffee, cocoa, cattle, palm oil, soy, rubber, and wood, along with over 800 derived product categories within the EU.

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Analyse Supply Chains, Identify Gaps and Minimise Risks

Like the Supply Chain Due Diligence Act (LkSG), the focus is shifting to the traceability of the entire supply chain and extensive due diligence obligations are arising including, provision of geolocation of areas of origin, ensuring deforestation-free production and compliance with the legislation of the country of production. For companies, this means they must precisely analyse the supply chains for certain product groups which, may lead to numerous questions:

  • Do you know the EUDR exposure of your company and its product groups and commodities?
  • Can you trace your procured commodities back to the area of production?
  • Do you know if the production was compliant with all the legislation of the country of production?
  • For certain commodities or products, can you substantiate that their production has not contributed to deforestation or forest degradation?
  • What steps are necessary to meet the EUDR requirements?
Infographic: Timeline for implementation of EUDR

Frequently asked questions

Non-SME operators and traders have until December 30, 2025, to review their global value chains and implement the due diligence obligations required by the EUDR. An extended deadline to June 30, 2026, applies to SME operators.

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 include leather goods, tires, seals, chocolate, roasted coffee, glycerine, soya oil, plywood, furniture and various paper and print products.

Due diligence includes the collection of information, including data on the geolocation of production areas, risk assessment and, if necessary, risk mitigation measures. As part of the risk assessment, in addition to assessing the risk of deforestation and forest degradation, aspects such as the involvement of indigenous peoples, compliance with the legislation of the country of production and mixing with non-compliant relevant products must also be analysed and evaluated. Based on the collection of information and risk assessment, companies are required to make a due diligence statement and take responsibility for compliance before marketing or exporting relevant commodities or products. 

The measures and procedures introduced by non-SME market participants and non-SME traders to fulfil due diligence obligations must also be reviewed and publicly reported at least annually.

Companies will now have to use the transition period to analyse their own procurement and product portfolios and identify any gaps. As with the 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. In addition to achieving compliance with the EUDR, companies can also benefit from transparency. This enables them to identify and proactively address risks and opportunities in their own supply chain.

If companies are unable to fulfil the required due diligence obligations, the commodities and products covered by the regulation can no longer be placed on the market. In addition to reputational risks, violations of the regulation also expose companies to massive financial risks, through:

  • Compulsory fines and penalties  
  • Temporary ban 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

Our services

Impact and gap analysis

Our initial step involves a thorough analysis of the affected products and entities within your organization. This foundational analysis helps us identify any data gaps that may exist. Additionally, we conduct an in-depth review of your existing system landscape and processes. Our goal is to propose resource-efficient and technology-driven strategies from the outset.

Strategic planning and measures

During the strategy phase, our interdisciplinary teams bring extensive expertise and years of experience to assist your company. We focus on embedding sustainability requirements into your existing supply chain strategy or advising on necessary adjustments. Furthermore, we provide guidance on strategic procurement measures to prepare your organization for future demands.

Operationalisation – implementation and control

This phase emphasizes the practical implementation of EUDR requirements. We identify and prioritize suitable measures for data collection and risk assessment of commodities and products. Our support extends beyond developing an implementation roadmap; we also introduce appropriate tools, collaboration opportunities, and, if desired, craft a bespoke due diligence system tailored to your needs.

EUDR reporting obligation

To meet the reporting obligations required by the EUDR, we support you with our expertise in external reporting requirements. We aid in the formalization and publication of necessary information, ensuring transparency throughout your supply chain that can be demonstrated both internally and externally.

Legal advisory and synergies

Our legal experts offer comprehensive advice on the legal aspects of EUDR implementation. We assist in creating compliance management policies, managing supplier and customer relations, with particular emphasis on contract adaptation and the formulation of codes of conduct. Additionally, we help establish grievance procedures and conduct legal reviews to identify potential implementation or liability gaps. Furthermore, we identify regulatory intersections and synergy potentials with other regulations, such as CSDDD, CSRD, and CBAM.

Webcast recording (German): Deforestation-free supply chain – challenges for industry and retail

In our webcast about deforestation-free supply chains and its challenges for industry and retail we provide an overview of the background and requirements facing your company so that you can prepare for the EUDR and identify areas where action is needed. Please note that at the end of December 2024, the EU agreed on a 12-month postponement of the start of application of the EUDR. The dates stated in the webcast are therefore no longer valid. The webcast is held in German.

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Your added value

With our holistic approach, we provide you with support throughout the entire process to meet the requirements of the EUDR. From identifying the products and business units affected by the EUDR, prioritising and strategically addressing existing gaps, to the optional design of your due diligence system, through to operationalisation and reporting – our experts are at your side with reliable advice and information.

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Contact us

Andreas Feiner

Andreas Feiner

Partner, Sustainability Services, PwC Germany

Tel: +49 171 8404662

Florian Pütz

Florian Pütz

Senior Manager, Sustainability Services, PwC Germany

Tel: +49 151 67255027

Dr. Tobias von Tucher

Dr. Tobias von Tucher

Partner, PwC Germany

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