Compliance

EU Deforestation Regulation

EU regulation requiring due diligence that goods placed on the market are deforestation-free and legally produced.

Aliases: EUDR, Regulation (EU) 2023/1115, 欧盟零毁林法规, 零毁林条例

Scope

The EU Deforestation Regulation, Regulation (EU) 2023/1115, covers seven commodity groups: cattle, cocoa, coffee, oil palm, rubber, soya and wood. It applies to the commodities and to a list of derived products, which is where consumer goods enter scope: leather, chocolate, furniture, printed paper, tyres and palm-oil-based ingredients among others.

The obligation is that relevant products are deforestation-free and produced in accordance with the legislation of the country of production. Both conditions must be evidenced.

Due diligence structure

Operators placing goods on the EU market must:

Collect information on the product, quantity, supplier and production plots, including geolocation
Assess and mitigate the risk of non-compliance
Issue a due diligence statement through the EU information system before placing the goods on the market

The geolocation requirement is the hardest part in practice, because it requires plot-level coordinates for the land where the commodity was produced, not a country of origin declaration.

Timeline and its revisions

Application dates for the regulation have been amended more than once, with the large-operator obligations and the small and micro-operator obligations separated in time. Further postponement proposals have been discussed. Because the dates have moved, sellers should confirm the date applicable to their company size in the current official text rather than relying on an earlier schedule.

Who is an operator

An operator is the party placing the product on the EU market, which may be the EU importer or a non-EU exporter acting on its own behalf. Traders further down the chain have lighter duties, but they must keep the due diligence reference and pass it on. The dates sit on the same legislative calendar as the EU customs reform package, so both are worth tracking together.

Interaction with other regimes

EUDR due diligence is separate from CBAM emissions reporting, from UFLPA forced-labour exposure in the United States, and from the customs data submitted under ICS2. A single supply chain can be in scope of several at once, and each requires its own evidence.

Practical preparation

Map the bill of materials to the regulated commodities, then work backwards to the plot. Suppliers who cannot provide geolocation will need to be replaced or requalified. Where the commodity is a minor input, such as palm oil in a cosmetic, the obligation still applies.

Primary source: Regulation (EU) 2023/1115; Commission guidance and information system documentation.

FAQ

Does EUDR apply to finished consumer products?

It applies to the commodities and to the derived products listed in the annex, which includes leather goods, chocolate, furniture, tyres and printed paper. A finished product is in scope when it contains a listed commodity in a listed form.

What is the geolocation requirement?

Coordinates of the plots where the commodity was produced, at a precision defined for plots above four hectares. A country-level or region-level statement does not satisfy it.

Are the application dates stable?

No. The dates have been amended and further postponement has been discussed. Check the current official text for the date applicable to your company size.

Do small sellers have the same obligations?

Small and micro operators have a lighter regime and different timing, but they still must issue or reference a due diligence statement for the goods they place on the market.

Is EUDR certification available?

There is no single certificate. Compliance rests on the due diligence statement and the evidence behind it, which may draw on certification schemes but is not replaced by them.