EUDR — EU Deforestation Regulation: due diligence, geolocation and timeline

What the EUDR prohibits

The regulation covers seven commodities (cattle, cocoa, coffee, oil palm, rubber, soya and wood) and the products listed in its Annex I that contain them, have been fed with them or have been made using them. These products may only be placed on the EU market, made available on it or exported if they are deforestation-free, were produced in accordance with the relevant legislation of the country of production, and are covered by a due diligence statement.

'Deforestation-free' means produced on land not subject to deforestation after 31 December 2020; for wood, also harvested without inducing forest degradation after that date. The 'relevant legislation' includes land use rights, environmental protection, labour and human rights, free, prior and informed consent, and tax, anti-corruption, trade and customs rules.

Due diligence in three steps

An operator first collects information: product description and quantity, country of production, geolocation of all plots of land, supplier and customer details, and verifiable information that the product is deforestation-free and legal.

Next comes the risk assessment, based on criteria such as the country's risk level, the presence of forests and indigenous peoples, the prevalence of deforestation, and concerns like corruption or document falsification. It must be documented and reviewed at least once a year.

If the risk is not negligible, the operator must mitigate it first, for example by requesting additional documents or commissioning independent audits. Only then is the due diligence statement submitted, and the operator takes responsibility for compliance by doing so.

Low, standard and high-risk countries

Implementing Regulation (EU) 2025/1093 lists the countries classified as low or high risk; every other country keeps a standard risk level. The four high-risk countries are Belarus, the Democratic People's Republic of Korea, Myanmar and the Russian Federation. The low-risk list includes all EU Member States and countries such as the United States, the United Kingdom, China, India and Vietnam.

When all commodities come from low-risk countries, operators can use simplified due diligence: no risk assessment or mitigation step, provided they have checked the complexity of the supply chain and the risk of mixing with products of unknown or higher-risk origin.

Simplified due diligence does not switch off vigilance: if the operator obtains information, including substantiated concerns, pointing to a risk of non-compliance or circumvention, the full risk assessment and mitigation obligations apply again.

What falls outside the scope

Products produced before 29 June 2023 are not covered. The production date is usually the harvest date, and for cattle products the date the animal was born.

Single-use packing material used only to support, protect or carry another product is excluded, as are reusable items such as pallets once used for that purpose. Packaging sold as a product in its own right remains in scope. Products made entirely from material that would otherwise be waste, such as furniture from timber recovered from a demolished building, are excluded too, but any virgin material they contain is covered. Containers that give a product its essential character are also in scope.

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