Are you ready for the European Deforestation Regulation (EUDR)?

The clock is ticking for companies covered by the European Deforestation Regulation (EUDR). This new European legislation aims to combat global forest degradation by banning high-risk products linked to deforestation from the European market. Palm oil, soya, coffee, cocoa, timber, rubber, cattle and their derivatives are central to it. With the compliance deadline fast approaching – 30 December 2025 for large and medium-sized companies and 30 June 2026 for smaller businesses – now is the time to make sure your organisation is prepared.

May 28, 2025

by

Katelijne Norga

Due Diligence

Deforestation poses a major threat to biodiversity, climate and human wellbeing. A significant share of global deforestation is driven by production in, or destined for, the European market. With strict regulation of the most critical commodities, the EUDR aims to address this.

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The regulation focuses on seven commodities often associated with deforestation: cocoa, coffee, palm oil, soya, timber, rubber and cattle. Derived products containing or produced using these materials are also covered, as listed in Annex I of the regulation. Examples include leather, chocolate, paper and furniture.

Traceability at the core

Under the EUDR, companies may not import, place on the EU market, or export any of the listed commodities unless they can prove that:

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the products are traceable back to the plot of land where they were produced;
no deforestation has occurred for their production since 31 December 2020;
the production complies with relevant legislation in the country of origin (e.g. environmental laws, human rights).

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Proving that your products are deforestation-free requires full traceability. Any volume of EUDR-covered products entering, being sold in, or exported from the EU must be 100% traceable to its place of origin. This means mapping all farms involved – from smallholder cocoa growers to large palm plantations – using GPS systems. The origin of these volumes must then be tracked at every stage of the supply chain.

Duty of care under the EUDR

Traceability goes hand in hand with the principle of duty of care or due diligence: a structured risk assessment that enables your company to identify where potential deforestation or degradation risks may arise in your supply chain. Based on this, you must take appropriate action to mitigate those risks. Due diligence is also a key requirement in other European laws, such as the CSDDD and CSRD.

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The EUDR defines four steps for due diligence: data collection, risk assessment, risk mitigation and public disclosure.

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1. Data collection

Collect all relevant information on the raw material or product in question, including volume, supplier, country of production, proof of legal harvesting and so on. A crucial element is the precise geographical coordinates of the plot where the raw material was produced.

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2. Risk assessment

Assess the risks associated with the product or raw material. This risk analysis must be repeated at least annually and is based primarily on the risk classification of the product region. To ensure consistent assessment, the European Commission has published a comparative list ranking all producing countries by deforestation and degradation risk: high, standard or low. Products sourced from low-risk regions (including all EU Member States, the US, China, Australia and Canada) are subject to simplified due diligence requirements. If you import from medium- or high-risk regions, more extensive due diligence is required. Currently, only Belarus, Russia, North Korea and Myanmar are considered high-risk.

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3. Risk mitigation

Where risks are identified, take appropriate and proportionate action. This may include requesting additional information, conducting (independent) audits, supporting local producers or taking forest protection measures. These procedures and measures should be reviewed at least once per year.

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4. Public disclosure

To demonstrate compliance, companies must submit a Due Diligence Statement (DDS), including the geographical coordinates and other required information, before placing a product on the EU market or exporting it.

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The European Commission has created an online information system for submitting and tracking DDSs via a unique reference number. The statements have legal value and can be audited by national authorities. A training server is available for companies to practice submitting their statements.

Which companies are affected?

All European businesses dealing with EUDR-covered products must comply, with different obligations depending on the type and size of the company:

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‍Market participants or operators are businesses that place a product on the EU market for the first time (e.g. importers of timber or coffee beans). This includes companies that transform one EUDR product into another – for example, chocolate manufacturers using cocoa.‍
Traders are businesses that buy and sell EUDR products already on the market, such as wholesalers and supermarkets.

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Every actor in the value chain is expected to apply a form of due diligence and keep records of their suppliers (upstream) and business customers (downstream). However, obligations are generally more extensive for operators than for traders, and for large companies than for SMEs. A balance has been sought between full traceability and application of due diligence throughout the chain on the one hand, and efficiency and administrative feasibility on the other.

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Downstream actors can usually rely on their supplier’s DDS, submitted when the product first entered the market. This avoids duplicate due diligence efforts. Operators further along the chain should mainly verify the accuracy of information provided by suppliers, for example through audits. Small traders are only required to keep records of where they obtained their products from and to whom they sold them.

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Key dates and deadlines

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31 December 2020

Cut-off date: no EUDR-covered product may come from land that was subject to deforestation or forest degradation after this date.

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30 December 2025

Full compliance required for large and medium-sized businesses.

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30 June 2026

Full compliance required for small and micro-enterprises.

What about SMEs?

SMEs using or marketing EUDR-covered products also have obligations. Companies are classified as SMEs if they meet fewer than two of the following thresholds:

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balance sheet total: ≤ €25 million
net turnover: ≤ €50 million
average number of employees: ≤ 250

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The obligations for SMEs are slightly less stringent. They are not required to conduct their own due diligence, but must:

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collect and retain contact details for their suppliers and business customers for five years;
store the reference numbers of their suppliers' DDSs.

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SMEs also have an additional six months to comply, with the deadline set at 30 June 2026.

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EUDR enforcement in Belgium

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In Belgium, the FPS Public Health is the designated authority for EUDR enforcement. Federal inspectors will conduct inspections. Belgium is also required, like other Member States, to report annually to the European Commission on its control plans, inspection outcomes and imposed penalties. Meanwhile, Belgium is transposing the EUDR into national legislation.

Not started yet, or unsure how to proceed? Pantarein can support you with tailored guidance. Contact us at mail@pantarein.be to explore your roadmap to EUDR compliance.