Environment & Sustainability

Operators or traders (excluding SMEs or micro-enterprises) placing, making available or exporting regulating commodities in the EU market must be able to prove they comply with the regulation.

30 December 2025, key provisions take effect.

Micro and small enterprises will enjoy a longer adaptation period, and other specific provisions.

For guidance on the transition period, please refer to the EU Commission’s FAQs at this link.

1. Collecting Information

To verify that relevant commodities/products are deforestation-free, the operator should provide geolocation coordinates allowing for the traceability of the plot of land where the commodity was produced.

If the plot of land is bigger than 4 hectares, the geolocation coordinates should be provided for each point of a polygon.

It is possible to provide a declaration in excess, that is, coordinates for several plots of land higher than those where the commodities were produced.

The operator’s responsibility extends to all geolocalised and declared plots of land, regardless of whether the commodity was effectively produced there.

Due diligence needs to be applied to all geolocalised and declared plots of land.

If one plot of the “geolocalised mix” is found to be non-compliant, the entire set of geolocalised plots of land is non-compliant.

2. Risk Assessment

Operators should provide adequately conclusive and verifiable information that the commodities/products are deforestation-free and in accordance with local legislation.

The EUDR does not set an official checklist of documents to be produced in the due diligence process. However, the below documentation should be included:

• Geolocation. There are no clear guidelines on how frequently the plot of land should be mapped.
• Date and time range of the production.
• Evidence that there hasn’t been any deforestation after 31 December 2020: Any map or system can be used as long as it is demonstrated to be the best source available.
• Evidence of no breach of local law: official guidelines from the European Commission are expected by the end of the second quarter of 2024.

Any organisation operating within the EUDR should set up a compliance programme and review its risk assessment at least once a year.

Operators and traders throughout the supply chain are liable for the information they use/provide in their due diligence systems and statements.

The obligations stemming from the EUDR do not apply to local producers; hence, they should be instructed on how to provide relevant information correctly.

Being certified by a third party is not enough to be compliant, although it can help to carry out the information collection and risk assessment.

3. Risk Mitigation

Unless the risk assessment shows that there is no or only a negligible risk that your products/commodities are non-compliant, the risk mitigation measures should include:

• Additional information.
• Independent survey/audits.
• Capacity building and investments.
• Compulsory compliance programme.

All decisions regarding risk mitigation need to be reviewed once a year.

4. Reporting

The final report should include:

• A summary of the product’s description, quantity and country of production.
• The conclusion of the risk assessment and mitigation measures taken and a description of the information and evidence used.
• Any consultation process needed with third parties, indigenous communities, etc.

Additionally, operators and traders should collect, organise and keep for 5 years:

• All the information gathered.
• Documentation showing how the due diligence process was carried out.
• Documentation on mitigation measures.
• Due diligence statements.

5. Due Diligence Statements

Operators and traders should provide due diligence statements through the EU Information System for each batch of commodity/product imported, placed/made available on the EU market or exported.