EU Deforestation Regulation (EUDR): New Compliance Requirements Explained

Let's see how EUDR impacts your organisation
Colleagues of the Custom team
If your organisation imports, exports or trades products such as wood, cocoa, coffee, rubber or a wide range of derived products, the EU Deforestation Regulation (EUDR) could affect your business. The regulation introduces new due diligence requirements designed to ensure that products placed on or exported from the EU market are not linked to deforestation or forest degradation. 

The EU Deforestation Regulation (EUDR) is a key element of the European Union’s sustainability agenda. Its objective is to ensure that products placed on the EU market, made available within the EU, or exported from the EU do not contribute to deforestation or forest degradation anywhere in the world.   

EUDR also requires that relevant products are produced in accordance with the applicable legislation of the country of production and respect fundamental human rights, including the rights of Indigenous Peoples. 
 

Understanding the impact of EUDR 

Introduced in two different phases according to company size, this EU law has major implications for companies that bring relevant products into the European market and/or export from the EU. 

In the event of non-compliance, there is a risk of fines, the confiscation of products and a negative impact on your company’s (ESG) reputation.  

Want to know more about our EUDR-services? Read our concise flyer .  

Key deadlines and latest developments 

Following the postponement adopted by the EU legislator and the simplification package agreed at the end of 2025, the EUDR will apply according to the following timeline:  

  • 30 December 2026: application for large and medium operators and traders, as well as micro and small operators already covered by the EU Timber Regulation (EUTR);  
  • 30 June 2027: application for micro and small operators.  

The latest guidance provides additional clarification on matters such as the different roles in the EUDR supply chain, obligations per role, geolocation requirements, re-imports, group structures, e-commerce transactions and the role of service providers.  

Although the implementation deadlines have been extended, preparing for EUDR can still be a significant undertaking. Mapping supply chains, collecting geolocation information, assessing risks and establishing robust due diligence procedures can take significant time, particularly for complex international sourcing structures.  

Which commodities are covered? 

Many organisations assume EUDR only applies to businesses trading raw materials. In practice, the scope is broader. 

The regulation covers commodities listed in Annex I of the Regulation:  

  • Cattle  
  • Cocoa  
  • Coffee  
  • Oil palm  
  • Rubber  
  • Soy  
  • Wood  

It also applies to many products derived from those commodities. Depending on the product and CN code involved, this may include furniture, paper products, chocolate, tyres and a range of other goods. Businesses should therefore assess their product portfolio carefully. 

In July 2026, the European Commission adopted a Delegated Act revising Annex I to simplify and clarify the product scope. Certain products were removed from scope, while others were added. These changes provide greater legal certainty and should reduce unnecessary administrative burdens for businesses.  

Risk classification and due diligence simplifications 

The Commission has also introduced a country benchmarking system that classifies countries according to their deforestation risk. Depending on the risk level assigned to the country of production, companies may benefit from a simplified due diligence process. Even where simplifications apply, organisations remain responsible for demonstrating compliance and maintaining the necessary supporting documentation. 

Recent guidance further confirms simplifications for downstream operators and traders, including streamlined reliance on due diligence already performed upstream in the supply chain where specific conditions are met.   

Rule of thumb 

Upstream operators are responsible for due diligence and DDS submission, while downstream operators and traders mainly have traceability, recordkeeping and notification obligations.  

Why should companies act now? 

Even with the extended implementation timeline, many organisations still face significant challenges:  

  • Identifying all affected products and suppliers
  • Collecting reliable geolocation data
  • Assessing supplier readiness
  • Implementing governance and compliance procedures
  • Integrating EUDR requirements into procurement, customs and trade compliance processes 
  • Preparing for audits and enforcement activities

Organisations that prepare early will be better positioned to manage compliance risks, avoid supply chain disruptions and demonstrate their sustainability commitments to customers, regulators and investors.

How BDO can help you 

Preparing for EUDR can involve multiple teams, suppliers and processes. Our Customs specialists can help you assess your exposure, understand your obligations and translate the requirements into practical next steps for your organisation. 

  • Scope and impact assessments 
  • Supply chain mapping 
  • Due diligence framework design 
  • Risk assessment methodologies 
  • Supplier questionnaires 
  • Internal procedures and governance 
  • Training and practical implementation support

Do you have questions about the impact of EUDR on your business? 

Reach out to one of our BDO Customs experts for pragmatic, business focused advice tailored to your organisation. 

Caroline Dorignaux

Senior Manager
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