EUDR: Good intentions, but complex in practice

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3 August 2025

The European Deforestation Regulation (EUDR) has a noble goal: to stop global deforestation by only allowing products on the European market that are free from illegal deforestation. There have been many complaints about its feasibility because it saddles SMEs in particular with a hefty administrative burden while it is international trade flows that contribute to global deforestation. Therefore, adjustments have come recently. Below is a brief overview of the (updated) requirements.

What is the EUDR?

The European Union Deforestation Regulation (EUDR), formally Regulation (EU) 2023/1115, is a European law that aims to ban products related to deforestation from the EU market. The law came into force on 29 June 2023 and shall apply from 30 December 2025 for large companies and from 30 June 2026 for small businesses.

To which products does the EUDR apply?

The regulation applies to the following raw materials and products (and derivatives thereof):

Cattle
Cocoa
Coffee
Wood
Palm oil
Rubber
Soy

Who does the EUDR apply to?

The law applies to:

Operators placing the above products on the EU market.
Traders reselling products within the EU.
Both domestic producers and importers are covered by this obligation.

Distinction by company size

The EUDR distinguishes on the basis of the business size, in accordance with Directive 2013/34/EU:

Type of company	Description (simplified)	EUDR obligations
Large companies	> 250 employees, > €40 mln turnover	Full due diligence + reporting
Small and medium-sized enterprises (SMEs)	≤ 250 employees	Due diligence required, but some reporting requirements relaxed
Micro-enterprises	≤ 10 employees or ≤ €2 mln turnover	Possible further exceptions (to be determined by Commission)

List of low- and high-risk countries

In May 2025, the European Commission published an official list of low- and high-risk countries:

Low risk: countries where there is relatively low risk of illegal deforestation. E.g. Netherlands, Germany, Ghana, Brazil (certain regions may still be high risk).
High risk: currently including Belarus, Russia, Myanmar, North Korea.
For countries without classification, the standard risk level applies.
For low-risk countries, a simplified due diligence procedure applies.

What does "due diligence" mean?

Market participants must be able to demonstrate that their products:

Being deforestation-free;
Comply with local legislation in the country of origin;
Be traceable to the plot where they were produced.

Documentation, GPS data and risk assessment are mandatory parts of this duty of care.

Important dates

Date	What?
29 June 2023	Entry into force EUDR
30 December 2025	Obligations take effect for large companies
30 June 2026	Obligations take effect for SMEs