Questions and answers to help you prepare for the EU Deforestation Regulation

Trading cocoa, coffee, soy, beef, palm oil, rubber or timber (or derived products, such as furniture and chocolate)? Get EUDR ready.

By Sjoerd Lopik

Expertise: Climate & Sustainability

01.05.2025

The Deforestation Regulation (EUDR) of the European Union (EU) may be one of the most significant legislative steps toward sustainability in global supply chains. The EUDR aims to prevent deforestation and forest degradation by directly targeting commodities often associated with these environmental issues. Targeted commodities include cocoa, coffee, soy, cattle, palm oil, rubber, and timber. The EUDR will replace the European Union Timber Regulation (EUTR), which aimed to curb the trade of illegally harvested timber.

In April 2025, the European Commission (EC) published updated guidance on EUDR Compliance (which you can find here).

In this Q&A, we will walk you through the most important EUDR requirements and update you on some of the most relevant developments to be distilled from the updated EC Guidance.

What companies are affected by the EUDR?
Does your business import, export, or trade one or more of the targeted commodities within the EU (i.e., cattle, cocoa, coffee, oil palm, rubber, soya, and wood)? Or does your business involve derived products of these commodities, such as furniture, leather, or chocolate? If so, you likely fall under the scope of the EUDR.

The EUDR distinguishes two relevant key players, namely ‘operators’ and ‘traders’. As the EC has clarified in its recent Guidance, an operator is any person who places a relevant product on the European market for distribution to commercial or non-commercial customers. Traders are identified as natural or legal persons in the supply chain who make the relevant products available on the market in the course of a commercial activity.

The EUDR distinguishes between SME and non-SME operators and traders. For all small, micro, and medium-sized corporations, obligations under the EUDR will only take effect in a simplified form.

Are you unsure whether your company needs to comply with the EUDR? The Dutch Food and Consumer Product Safety Authority (NVWA) has introduced a questionnaire that helps identify which rules apply for your company (find the questionnaire here).

What does the EUDR entail for my business?
Most importantly, companies placing products linked to the mentioned commodities on the market within the Netherlands are expected to share information with the NVWA on the origin of the product, the risks associated with the product and any mitigation measures to be taken. This should be done in through a due diligence statement (zorgvuldigheidsverklaring). This statement must be created through TRACES, an online compliance application of the EU. In this statement, you must declare that there is no, or negligible risk of deforestation associated with your products. Without a properly submitted and substantiated due diligence statement, placing the product on the EU market is prohibited.

This means your company is obliged to comply with the following aspects:
  1. Due diligence. Pursuant to Article 8 of the EUDR, businesses are required to implement due diligence measures and recognize when mitigation measures are necessary. To comply, businesses should create an action plan that includes risk reduction strategies, such as sourcing from certified sustainable suppliers. Specific criteria for the mandated risk assessments are set out in the recent Guidance by the EC.
  2. Traceability. As part of the due diligence measures, companies must establish precise traceability systems for the commodities they handle. This includes information on the exact geographical location of the product's origin, extending to farm or plantation level. Digital tools for supply chain traceability may be important for your company.
  3. Supplier engagement. As Article 4 of the EUDR sets out, EU-based operators bear responsibility for the compliance of any relevant products. However, product compliance may lie outside of your direct sphere of control. Therefore, clearly inform suppliers of your compliance needs, and embed EUDR obligations directly into supplier contracts and codes of conduct. Regular supplier audits and training may also help to ensure compliance.
  4. Documentation and reporting. Maintain thorough records and reports to demonstrate compliance measures. EU authorities may carry out checks and audits to enforce the EUDR (Article 17 through 19 of the EUDR). For large companies, yearly reports are mandated (Article 12 of the EUDR). Clear and transparent documentation will be key to avoid issues in this area.

What risks are associated with non-compliance?
Products that are non-compliant with the EUDR may not be placed on the European market. Failure to comply with the EUDR poses serious risks, ranging from reputational damage to product bans and financial penalties. The EC will oversee EUDR compliance, supported by national regulators such as the NVWA and customs authorities. The risk of litigation and legal disputes is considerable, also given the fact that NGOs are expected to be monitoring compliance alongside the EC (as they already did under the EUTR). As was the case under the EUTR, businesses should expect the NVWA to be active when it comes to enforcing the EUDR. In recent years, the NVWA has actively enforced the EUTR. Even criminal prosecution is a possibility for companies involved in illegal practices related to deforestation.

When should I act?
Now. After one year of delay, the EUDR is set to apply as of 30 December 2025 for larger and medium companies and as of 30 June 2026 for micro and smaller businesses. From that date on, you must be able to prove that imported, exported, or traded commodities within the EU do not contribute to deforestation.

Ensuring compliance means maintaining clear documentation and developing a comprehensible strategy and roadmap for due diligence. This can be time-consuming. That’s why we recommend starting compliance efforts without delay.

De Roos can help your business understand what is required for EUDR compliance, create a tailored plan for achieving compliance, and update your supplier contracts and code of conduct. That way, you can ensure that your company stays on top of these important regulatory developments.

Sjoerd Lopik

Investigations & Enforcement

Lisette van der Linde

Climate & Sustainability

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