Please refer to the EUTR for wood and wood products harvested before June 29, 2023. After June 29, 2023, please refer to the EUDR information below.
The European Union (EU) has revised its regulatory framework for timber supply chains as part of its efforts to act on deforestation linked to agricultural commodities. On May 31, 2023, the EU passed Regulation (EU) 2023/1115, otherwise known as the EU Regulation on Deforestation-free Products (EUDR). The scope of the EUDR includes wood and wood products covered under the EU Timber Regulation (EUTR), and six agricultural commodities, cattle, cocoa, coffee, oil palm, rubber and soy and covered derivatives, as defined under Annex I. Under the EUDR, all operators and traders that make available these commodities and/or covered derivatives on the EU market, or export such products from the EU, must prove that these products were not produced on recently deforested land or contributed to forest degradation.
Major updates: EUDR
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European Parliament votes to delay the EUDR’s entry into force for the second time (December 2025)
Members of the European Parliament voted on December 17, 2025, to delay the EUDR’s entry into application by an additional 12 months. The implementation date is now December 30, 2026, for large corporations and June 30, 2027, for micro and small enterprises.
The amendment passed by the Parliament includes simplification measures for downstream operators and traders as well as micro and small primary operators, namely:
- A new category of operators: ‘downstream operators’ – which shares the same obligations as traders;
- Downstream operators and traders will no longer need to submit due diligence statements.
- A new category of operators: ‘Micro or small primary operators’ will now only have to submit a one-time simplified declaration. These operators are also no longer required to provide geolocation of all plots of land in which the product or commodity was produced or derived from, and instead, can provide the postal address of the plot in question; and
- The obligation to submit a simplified declaration is waived if the commodities and/or derived products are already covered by traceability or reporting obligations along the supply chain.
Other simplification measures introduced in the amendment include:
- A requirement for the European Commission to carry out a simplification review of the Regulation by April 30, 2026, to evaluate the administrative burden and impacts on micro and small enterprises;
- The exclusion of printed materials, such as books and newspapers, from Annex I – which removes all EUDR obligations and requirements for such products.
European Parliament votes to object to the European Commission's benchmarking system (July 2025)
Members of the European Parliament voted on July 9, 2025, to object to the benchmarking system. However, the vote is not legally binding and is purely indicative, meaning for now the EUDR timeline remains on track.
REPEALED: Amendments to the EUDR (December 2024)
On December 18, 2024, the EU amended the EUDR (Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) 2023/1115 as regards provisions relating to the date of application), postponing its application by 12 months. Therefore, obligations for operators and traders are now set to come into effect on December 30, 2025 (rather than December 30, 2024). Micro, small and medium-sized enterprises (SMEs) have a longer preparation period until June 30, 2026 (rather than June 30, 2025).
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The Regulation
The Regulation was signed on May 31, 2023, and entered into force on June 29, 2023.
Relevant commodities and their covered derivatives must meet three conditions to be placed and/or made available on the EU market or exported:
- They are deforestation-free, with products produced on land that has not been subject to deforestation or degradation after December 31, 2020.
- They have been produced in accordance with the relevant legislation of the country of production.
- They are covered by a due diligence statement. Operators assume responsibility for the compliance of the commodity and/or covered derivative through the due diligence statement.
Wood and wood products covered by a valid FLEGT license are considered compliant with the legal production requirement but not the deforestation-free/degradation-free requirement.
Certification or other third-party verified schemes can be used in the risk assessment procedure, but they cannot substitute due diligence and do not constitute compliance with the Regulation (Article 10.1(n); Preamble (52)).
Due diligence
The Regulation requires operators to establish and implement a three-step due diligence system to minimize the EU’s contribution to deforestation and forest degradation globally. The system must be reviewed at least once a year. The requirements are slightly different for SMEs versus other operators and traders, as described below:
Operators
- Information gathering: Operators must collect data, documents, and information, including details on their suppliers and details on the operator and/or trader to whom they have supplied commodities, and/or their covered derivatives, descriptions and quantities of the product, the country of production, geolocation of all plots of land in which the product or commodity was produced or derived from, and adequately conclusive and verifiable information that the products are deforestation-free and produced in accordance with the legislation of the country of production. This information must be kept for five years from the date of export or placing on the market.
- Operators may refer to due diligence statements that have already been submitted for relevant commodities and/or their covered derivatives, but they are required to check that due diligence was carried out in accordance with the Regulation.
- Risk assessment: Operators must verify and analyze the information collected during the first step. The risk assessment establishes whether there is a risk that the products intended for placement on the EU market or export are non-compliant. Several criteria must be considered in the risk assessment, including but not limited to the presence of forests and Indigenous Peoples, substantiated concerns, and prevalence of deforestation or forest degradation in the country of production. Operators must document and review the risk assessments at least annually and make them available to the competent authorities upon request.
- Risk mitigation: If the risk assessment determines that the commodities or covered derivatives potentially have a risk of being associated with the deforestation or degradation, operators must carry out risk mitigation procedures and measures to achieve no or negligible risk. Examples of risk mitigation include collecting additional information, conducting independent audits and surveys, and supporting compliance, especially for smallholders through capacity building and investments.
Operators must submit due diligence statements through the information system established by the European Commission.
Downstream Operators and Traders
Downstream operators and traders are not required to ascertain that due diligence was exercised or have obligations to submit due diligence statements. However, they are still required to register in the information system and all first downstream operators or traders, regardless of being a small or medium-sized enterprise, should ensure full traceability by collecting reference numbers of due diligence statements and declaration identifiers assigned to micro or small producers. This obligation to collect and keep reference numbers only applies to the first downstream operator or trader and no other downstream operators or traders within the supply chain.
Downstream operators and traders should only place, make available or export commodities or their covered derivatives if they possess the required information established in the Regulation.
Micro or small primary operators
Micro or small primary operators are required to submit a one-time simplified declaration in the information system which will issue these operators a declaration identifier that should accompany the commodities and their covered derivatives placed on the market or exported by micro or small primary operators.
When submitting the one-time simplified declaration, micro or small primary operators are no longer required to provide the geolocation of plots of land where the commodities or their covered derivatives come from, and instead, can provide the postal address of the location of the plot(s) of land.
In cases where the required information and data are already stored in Member States’ national databases, micro or small primary operators are exempted from the obligation to submit a simplified declaration.
SMEs
SME operators
SMEs are not required to exercise due diligence for commodities and their covered derivatives that have already been subject to due diligence and for which a due diligence statement has already been submitted. SMEs shall provide the competent authorities with the reference number of the due diligence statement upon request. Otherwise, the SME operator must conduct due diligence in accordance with the Regulation.
- Information gathering: SME operators must collect data, documents, and information, including details on their suppliers and details on the operator and/or trader to whom they have supplied commodities, and/or their covered derivatives, descriptions and quantities of the product, the country of production, geolocation of all plots of land in which the product or commodity was produced or derived from, and adequately conclusive and verifiable information that the products are deforestation-free and produced in accordance with the legislation of the country of production. This information must be kept for five years from the date of export or placing on the market.
- Risk assessment: SME operators must verify and analyze the information collected during the first step. The risk assessment establishes whether there is a risk that the products intended for placement on the EU market or export are non-compliant. Several criteria must be considered in the risk assessment, including but not limited to the presence of forests and Indigenous Peoples, substantiated concerns, and prevalence of deforestation or forest degradation in the country of production.
- Risk mitigation: If the risk assessment determines that the commodities or covered derivatives potentially have a risk of being associated with deforestation or degradation, operators must carry out risk mitigation procedures and measures to achieve no or negligible risk. Examples of risk mitigation include collecting additional information, conducting independent audits and surveys, and supporting compliance, especially for smallholders through capacity building and investments.
SME traders
SME traders do not need to carry out due diligence, but instead, must collect data, documents and information including the name and details of the operators or traders who have supplied the commodities and/or their covered derivatives to them, as well as the reference numbers of the due diligence statements associated with those products and the name and relevant details of the operators or traders to whom they have supplied the commodities and/or their covered derivatives. This information must be kept for at least five years from the date of making available on the market.
For more information about the due diligence process, see the European Commission’s Due Diligence webpage.
Country Benchmarking
The EUDR establishes a three-tiered system to assess the deforestation and forest degradation risk of countries or parts thereof. The assessment of risk is based on the rate of deforestation and forest degradation, rate of expansion of agriculture land for relevant commodities, and production trends of commodities and their covered derivatives.
Other information may be considered, including progress related to nationally determined contributions (NDCs) in the country of concern and/or implementation of agreements and other instruments between the concerned country and EU Member States on deforestation and forest degradation. When the EUDR was passed, the European Commission assigned a standard risk rating to all countries.
In May 2025, the European Commission published the Regulation's benchmarking classification system, based on the criteria laid out in Article 29. The ranking system was designed to help businesses and enforcement authorities in the EU conduct due diligence and enforce compliance. The Commission will notify countries designated as high risk and will engage in dialogue with the objective of reducing their level of risk. The risk rating is subject to change over time.
- High risk: Countries, or parts thereof, that are determined to have a high risk of producing commodities and/or covered derivatives that do not comply with the Regulation’s deforestation-free requirement.
- Low risk: Refers to countries, or parts thereof, in which there is sufficient assurance that instances of producing commodities and/or covered derivatives that do not comply with the deforestation-free condition are exceptional.
- Standard risk: Countries, or parts thereof, that do not fall into the high-risk or low-risk categories.
Regardless of country risk ratings, all products to be placed and/or made available on the EU market or exported must be accompanied by a due diligence statement including geolocation information or a simplified declaration. The percentage of checks undertaken by EU Member State competent authorities will depend on the country’s risk rating. According to the 2025 amendment, the percentage of checks are as follows:
- High risk: Annual checks will cover at least 9% of operators, downstream operators and traders classified as high risk, as well as 9% of the quantity of commodities and derived products.
- Low risk: Annual checks will cover at least 1% of operators, downstream operators and traders classified as low risk.
- Standard risk: Annual checks will cover at least 3% of operators, downstream operators and traders classified as standard risk.
Substantiated Concerns
Natural or legal persons may submit substantiated concerns to competent authorities when they consider that one or more operators or traders are not complying with the Regulation. Competent authorities are mandated to assess the substantiated concerns and take necessary steps to determine potential non-compliance. Within 30 days of receiving the substantiated concern, competent authorities shall inform the person(s) who submitted the concern of the follow-up (Article 31). The public shall have access to administrative or judicial procedures to review the legality of decisions, acts, or failures to act of the competent authorities.
Following a substantiated concern, operators, traders and SME traders are obligated to inform the competent authorities of the Member States in which they placed the relevant product on the market, as well as traders to whom they supplied the product of a commodity and/or covered derivative, that the product in question placed on the market may be non-compliant. Operators, traders and SMEs are required to comply with information requests/checks (documents, etc.) from competent authorities.
Enforcement
Competent authorities designated by their respective Member State must regularly carry out checks on operators and traders to verify compliance with the EUDR within their territory. The competent authorities use a national risk criterion that considers several factors, including the commodities, complexity of supply chain, and assessed risk of the country of production (see Country Benchmarking above) to carry out the annual checks. The competent authorities will log information regarding the checks in the information system alongside the due diligence statements.
Penalties
Infringements of the Regulation by operators and traders are subject to penalties. Information on persons found to have infringed the Regulation will be published on the European Commission’s website. Member States are responsible for establishing rules on penalties applicable to infringements of the Regulation (Article 25(1)).
The following are applicable penalties for EUDR infringements:
- Fines proportionate to the environmental damage and the value of the relevant commodities and/or their covered derivatives concerned. For legal persons, the maximum amount of this fine shall be at least 4% of the operator’s or trader’s total annual EU turnover in the financial year preceding the fine decision;
- Confiscation of the commodity and/or its covered derivative from the operator and/or trader;
- Confiscation of revenues gained by the operator and/or trader from a transaction with the commodity and/or the covered derivative concerned;
- Temporary exclusion for a maximum period of 12 months from public procurement processes and from access to public funding, which includes tendering procedures, grants and concessions;
- Temporary prohibition from placing or making available on the market or exporting commodities and their covered derivatives in the event of a serious infringement and/or repeated infringements; and
- Prohibition from exercising simplified due diligence in the event of a serious infringement and/or repeated infringements.