June 9, 2025
The European Commission has released new guidance documents to simplify the implementation of the EU Deforestation Regulation (EUDR), which will take effect at the end of 2025. This comes after EU authorities agreed in late 2024 to postpone implementation by a year to give global stakeholders more time to prepare.
The EU Deforestation Regulation sets mandatory limits for all companies who sell, produce, trade, or export products containing palm oil, beef, timber, coffee, cocoa, and soy from the EU market. These due diligence rules also apply to several derived products. After two years, EU authorities plan to review the regulation to determine whether more products need to be listed.
Under the regulation, retailers will also be required to trace products they sell back to the plot of land where they were produced. The rules seek to reduce the administrative burden for retailers and administrators, but international stakeholders quickly raised concerns that the rule would be burdensome and costly to implement.
Details of the new documents
In addition to updated guidance, the Commission also released Frequently Asked Questions (FAQs). Both documents are intended to provide companies, national authorities in EU Member States, and partner countries with simplified measures to demonstrate that their products are deforestation-free. The Commission incorporated significant stakeholder input and states that these documents will “guarantee harmonised implementation of the law across the EU.”
The Commission identifies several key steps in the new guidance documents, including several that specifically ease the burden of due diligence statements:
- Large companies will be allowed to reuse existing due diligence statements when goods that were previously on the EU market are reimported. The Commission notes this means that less information needs to be submitted in the IT system.
- Companies may submit due diligence statements annually instead of for every shipment or batch of products placed on the EU market.
- Multiple traders and operators may appoint the same authorised representative, who can now submit due diligence statements on behalf of members of company groups.
- Downstream operators and traders can now refer to due diligence statements of their upstream suppliers, provided they have ascertained that due diligence has been carried out. According to the Commission, this carries a minimal legal obligation for downstream companies of collecting reference numbers of Due Diligence Statements (DDS) from their suppliers and using those references for their own DDS.
Beyond the guidance documents, the Commission also published a Delegated Act addressing Annex I on 15 April 2025 for public consultation. The act outlines additional clarifications and simplification on the EUDR’s scope and addresses requests from stakeholders for guidance on specific categories of products. The Commission hopes it will “avoid unnecessary administrative costs for economic operators and authorities.”
Finally, the Commission confirmed it is finalising the new benchmarking system under which third countries and EU Member States are assigned a low, standard, or high level of risk related to deforestation. The Commission plans to adopt an Implementing Act for the system no later than 30 June 2025.
Looking ahead
Companies should closely review the new guidance documents and FAQs and engage in the stakeholder process to provide feedback on the Delegated Act. While the implementation has been delayed until 30 December 2025 for large operators and traders and 30 June 2026 for micro- and small enterprises, companies should continue their efforts to implement the EUDR’s provisions.
Additionally, companies should use the extra time before the EUDR enters into force to ensure they are fully compliant with other measures in the regulation. It would also be prudent to audit supply chains to ensure all aspects of their product’s life cycle are adhering to the new rules.
The Commission’s actions with the EUDR are one of several attempts at streamlining and simplifying compliance measures as part of the EU’s push to be more competitive. It has also recently loosened reporting obligations under the Corporate Sustainability Reporting Directive and amended the EU Taxonomy and the Carbon Border Adjustment Mechanism (CBAM). Companies should closely monitor for further changes that reduce their regulatory burden.
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