A public consultation on the draft Delegated Regulation is open until May 13, 2025, allowing stakeholders to provide feedback on the EUDR’s scope and proposed limitations.

The European Union has enacted the EU’s Deforestation Regulation 2023/1115 (EUDR) to combat deforestation, aiming to mitigate climate change, preserve biodiversity, and enhance climate resilience.

Effective from June 29, 2023, the EUDR mandates that certain high-risk commodities cannot be traded in the EU unless they are deforestation-free, legally produced, and accompanied by a due diligence statement.

The regulation applies to commodities such as cocoa, coffee, palm oil, soy, wood, cattle, and rubber, with the potential for expanding this list after a review period of two years.

Due diligence obligations under the EUDR apply to individual entities rather than corporate groups, meaning that an entity's status as a small or medium-sized enterprise (SME) is assessed individually.

Re-importers of previously exported goods are classified as downstream operators and have specific simplified due diligence obligations based on their size, with SMEs exempt from detailed requirements.

Non-SME downstream operators and traders can reuse existing due diligence statements for products previously on the market, which simplifies compliance processes.

The EUDR Guidance introduces a significant reduction in administrative burdens, estimating a 30% decrease in compliance costs for companies.

The updated EUDR Guidance clarifies that only products made from relevant commodities are subject to the regulation, proposing exemptions for samples used for testing and analysis.

Companies can submit annual due diligence statements covering multiple shipments, provided they comply with quantity and timing requirements.

On April 15, 2025, the European Commission updated the EUDR’s FAQ Document and Guidance Notice to assist companies in complying with the regulation's obligations.

The Commission's approach to ESG legislation indicates that compliance and reporting obligations will continue to evolve, promoting a harmonized regulatory framework for sustainable supply chains.