EUDR European Union Deforestation Regulation

Navigating the Path from Risk to Readiness

The European Union states that its European Union Deforestation Regulation (EUDR) represents a landmark piece of legislation aimed at ensuring that products placed on the EU market do not contribute to deforestation or forest degradation. Following extensive stakeholder consultation and system development, the European Commission has announced significant changes and updated implementation timelines in December 2025 to ensure smooth, effective compliance, with further implications to follow before April 2026. Importers and exporters can take this additional time to verify that their supply chains are prepared.

Operators and traders must take steps to verify that their goods do not result from recent deforestation, as non-compliant products cannot be sold within the EU. Failure to comply carries significant risks, including:

Financial Penalties: Fines of up to 4% of the annual EU-wide revenue
Confiscation: Seizure of relevant products and revenues
Market Exclusion: Temporary prohibition from trading these products within the EU or participating in public procurement

As a leading provider of sustainability services, Bureau Veritas supports businesses in navigating the EUDR. Our expertise in supply chain auditing and traceability helps companies demonstrate compliance and access opportunities in the EU market.

Regulatory Overview & Key Timelines

The EUDR places restrictions on specific commodities and their derived products to ensure they are "deforestation-free".

Covered Commodities: Cattle, cocoa, coffee, palm oil, rubber, soya, and timber (The EUDR applies to 7 key commodities and their derivatives where the product HS code is in the Appendix I)
The Cut-off Date: Products must not have been produced on land deforested or degraded after December 31, 2020
Updated Implementation Dates:
Large and Medium Enterprises: December 30, 2026
Micro and Small Enterprises (SMEs): June 30, 2027
Companies shall watch out for the updates to be announced by the European Commission by 30th April, 2026 (https://www.consilium.europa.eu/en/press/press-releases/2025/12/18/deforestation-council-signs-off-targeted-revision-to-simplify-and-postpone-the-regulation/)

Major Regulatory Simplifications (December 2025 Update)

The Commission has introduced measures to reduce administrative burden by approximately 30% as estimated by the Commission:

Streamlined Reporting: Only one due diligence statement is required per batch at the point of first market entry, rather than multiple submissions throughout; downstream operators using that batch do not need separate submissions
Simplified Declarations for Micro/Small Operations: Micro and small primary operators can submit a simple, one-time simplified declaration in the EUDR IT system

The Four Pillars of Due Diligence

To comply with EUDR, operators shall establish a due diligence system consisting of 4 elements:

Information Collection: Gathering product descriptions, quantities, and the geolocation coordinates of the specific plot of land where the commodity was produced
Risk Assessment: Evaluating the risk of non-compliance based on country risk levels, supplier history, and potential for mixing with non-compliant products
Risk Mitigation: If a risk is identified as "greater than negligible," companies shall implement measures such as gathering extra information or conducting field audits
Documentation: Maintaining a due diligence system and keeping records for at least 5 years

Our Practical Solutions

BV CPS EUDR solution is built around a due diligence framework, providing an end-to-end compliance solution that transforms overwhelming regulatory obligations into manageable, actionable compliance tasks. The modular, flexible service allows customers to choose either the full suite or only the steps where you need help.

1. Readiness Assessments

Your Challenge: You do not know which suppliers have complete data, nor can you be sure that the information is accurate.

What BV Deliver:

Supply Chain Mapping: Identify all suppliers and trace the origins of commodities, either with or without the support of an IT platform
Document Verification: Validate supplier provided documents related to product identification, risk assessment, risk mitigation, and chain of custody
Risk Profiling and Geolocation verification: Assess deforestation risk across your supply base

2. Supplier Engagement and Training

Your Challenge: Suppliers do not understand the EUDR requirements. You have identified areas of risk and information that are missing.

What BV Delivers:

OneSource Academy Training Programs: Enjoy unlimited access to all self‑paced, interactive online BV expert-led courses available in multiple languages with a single subscription—available in both monthly and annual plans [Sign up to learn more]
Live Workshops: Instructor-led training for brands/retailers and suppliers
Corrective Action Support: Step-by-step remediation plans for at-risk suppliers
Corrective Action Plans Tracking: Real-time monitoring via BV OneSource Connect platform; escalation management for non-responsive suppliers
On-site Audits: Conduct field verification of high-risk suppliers (standard/high-risk countries or significant gaps)

3. Ongoing Compliance Support

Your Challenge: EUDR compliance is not a one-time exercise. Your supply chain is subject to change (new suppliers, exits and changes in risk). You need to stay compliant.

What BV Delivers:

Annual Reviews: Periodic assessment of due diligence effectiveness
Regulatory Updates: Keep you informed of evolving guidance and simplifications
Audit Preparation: Ready your organization for competent authority inspections
Training Programs: Build internal capacity for sustained compliance

EUDR FAQs:

What is EUDR and why does it affect my business?

EUDR requires all companies selling products into or exporting from the EU to prove their commodities (cocoa, coffee, palm oil, soya, rubber, wood, cattle) are "deforestation-free” – produced on land not deforested after December 31, 2020. Non-compliance carries penalties up to 4% of your EU-wide revenue, product confiscation, and trading bans.
Which of my products are covered by EUDR?

The EUDR covers seven commodities: cocoa, coffee, palm oil, soya, rubber, wood and cattle. However, the regulation also applies to finished products containing these materials. Please refer to Annex I of the regulation for details of your specific product categories.
How do I know what my obligations are under EUDR?

All operators or traders working in the European market that import or export the relevant products in Annex I are affected. EUDR obligations differ depending on where the company stands in the supply chain and on the size of the company.
What does EUDR due diligence consist of?

Despite recent simplifications, the core due diligence obligations still include gathering information, assessing and mitigating risks, maintaining records of the due diligence process, and submitting due diligence statements to the EU information system. Operators sourcing from countries classified as low risk under the EU country classification list are exempt from the full due diligence obligations set out in Articles 10 and 11.
How will certifications (FSC/PEFC) relate to the EUDR?

Industry schemes such as FSC (Forest Stewardship Council) and PEFC (Programme for the Endorsement of Forest Certification) are aligning their modules to support EUDR requirements.
However, these certifications do not replace the legal requirement to create and submit a Due Diligence Statement (DDS). They are valuable tools for risk assessment and mitigation but are not a substitute for the official regulatory process.

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