EU Deforestation Law (EUDR): Products, Proofs & Deadlines

Published: August 9th 2025, 12:30
Category: Trade & Agriculture

Illustration of a rainforest with containers nearby by LeonardoAI

What the Law Covers

EUDR applies to seven commodities linked to deforestation: cattle, cocoa, coffee, palm oil, rubber, soy and wood. It also applies to a wide list of derived products (e.g., leather, chocolate, tyres, furniture, pulp/paper). To be compliant, products must be deforestation-free and legally produced.

Summary

What’s covered: cattle, cocoa, coffee, palm oil, rubber, soy and wood — plus many derived products (e.g., beef, chocolate, tyres, furniture).
Proofs required: geolocation coordinates for every plot; file a due diligence statement in the EU’s EUDR Information System.
Deadlines: large operators & traders from 30 Dec 2025; micro/small companies from 30 Jun 2026.
Penalties: fines up to 4% of EU turnover, plus possible confiscation/exclusion from public contracts.
Deforestation-free rule: no production on land deforested after 31 Dec 2020.

What Companies Must Do

Map supply chains: identify plots of land for each input; collect geolocation coordinates (points or polygons).
Assess risk: check deforestation after 31 Dec 2020, legality in the country of production, and supply-chain integrity.
Mitigate risk: request extra evidence, switch suppliers, or split high-risk lots.
File a Due Diligence Statement (DDS): submit via the EUDR Information System before placing on the EU market or exporting.
Keep records: retain data and documents for authorities (typically at least five years).

Dates That Matter

30 Dec 2025: Large operators and traders must comply (DDS + geolocation; checks may be risk-based).
30 Jun 2026: Micro and small companies must comply.
Country benchmarking: the EU’s risk-label system is not in place after Parliament objections, so expect case-by-case checks in the interim.
Information System: the EU platform for submitting DDS is rolling out; operators should onboard early.

Compliance Checklist

Scope & role: Are you in EUDR scope? Operator or trader; micro/small vs large.
Geolocation: Get coordinates for every plot (point/polygon) from suppliers.
Cutoff & legality: Evidence of no post-31 Dec 2020 deforestation + legal production docs.
Risk → mitigation: Assess risk; if not negligible, gather extra proof or change suppliers—document it.
DDS & records: Submit the Due Diligence Statement before placing on market; keep files 5+ years.

Who Pays — and Who Gets Hit

Smallholders & co-ops outside the EU: GPS mapping of plots, polygon data, and document workflows raise costs and require training.
Importers & traders: mixed lots become risky if any sub-lot lacks coordinates or proof; expect suppliers to be dropped.
SMEs: compliance is delayed but not waived; templates and shared tools are essential to avoid duplication.
Consumers: short-term price pressure is likely in cocoa/coffee and rubber-heavy goods while supply chains re-route.

Controversies & Risks

Delay and uncertainty: a one-year delay gives time to prepare, but last-minute changes (like benchmarking objections) muddy enforcement.
Customs capacity: competent authorities need tooling to parse geodata and flag risk without choking trade.
Smallholder exclusion: buyers may avoid small farms that can’t provide clean polygons, pushing them out of EU markets.
“Green protectionism” claims: producer countries argue the rules act as a trade barrier; expect pushback and diplomatic friction.

Policy Alternatives

Pilot lanes first: phase compliance by corridor and commodity, with published pass/fail metrics.
Smallholder carve-outs: allow credible group polygons + satellite attestations for micro-farms during a transition window.
Certification + satellite combo: accept robust third-party schemes when paired with plot-level geodata and satellite checks.
Open tooling: an EU-maintained API and templates for DDS files to cut SME admin time.

Quick FAQ

Do I really need coordinates for every plot? Yes. Operators must provide geolocation data for all plots supplying covered commodities.
Is certification enough? No. Certifications can support risk assessment, but you still need geolocation and a DDS.
Are mixed shipments allowed? Only if every sub-lot is traceable and deforestation-free; otherwise expect detentions or rejections.
What are the penalties? Fines up to 4% of EU turnover, plus possible confiscation and exclusion from public contracts.
What are the current deadlines? Large operators/traders: 30 Dec 2025. Micro/small: 30 Jun 2026.

Final Thoughts

EUDR aims to clean up supply chains. The risk now is red tape without focus. Get the data tools, pilots and smallholder pathways right, and the law can bite where it matters—without breaking the people who feed the system.