Understanding the EUDR

What is the EUDR?

The EUDR (EU Deforestation Regulation) is a European Union regulation established by Regulation (EU) 2023/1115 of 31 May 2023 (OJEU L 150, 9.6.2023). It replaces and significantly strengthens the former EU Timber Regulation (EUTR, Regulation 995/2010), which applied only to timber and timber products.

Its core objective: ensure that products placed on or exported from the EU market have not contributed to deforestation or forest degradation worldwide. The EUDR introduces a comprehensive due diligence system for seven key agricultural commodities and their derived products.

Why the EUDR exists

Global deforestation remains one of the leading drivers of biodiversity loss, climate change, and indigenous rights violations. The EU is responsible for approximately 16% of global deforestation linked to international trade -- the second largest contributor after China.

The regulation addresses three interconnected challenges:

1. Climate change mitigation: deforestation accounts for roughly 11% of global greenhouse gas emissions. Halting deforestation is essential to meet the Paris Agreement targets and the EU's own Green Deal commitments.
2. Biodiversity protection: forests host approximately 80% of terrestrial biodiversity. Agricultural expansion is the primary driver of habitat loss in tropical and subtropical regions.
3. Market-level accountability: the EUTR was limited to timber and proved insufficient. Enforcement was uneven across Member States, and commodities like soy, palm oil, and cattle -- responsible for the majority of deforestation -- were not covered at all.

Legal basis and structure

The EUDR is based on Article 192(1) TFEU (environmental policy). It is structured around:

• A prohibition (Article 3): no relevant commodity or product may be placed on, made available on, or exported from the EU market unless it is deforestation-free, produced in accordance with the relevant legislation of the country of production, and covered by a due diligence statement.
• A due diligence system (Articles 8-12): operators must collect data, assess risk, and mitigate that risk before placing products on the market.
• A cut-off date (Article 2): 31 December 2020. Products must come from land that was not deforested after this date.

Replacing the EU Timber Regulation

The EUDR repeals Regulation (EU) 995/2010 (EUTR) in its entirety. Key differences:

The shift from "legality only" to "deforestation-free" is fundamental: a product can be legally produced under local law yet still originate from recently deforested land. The EUDR closes this gap.

Timeline and key dates

Adoption and entry into force

• 29 June 2023: Regulation 1115/2023 published in the Official Journal
• 29 June 2023: Entry into force (20 days after publication)
• 30 December 2024: Original application date for large operators (18 months after entry into force)
• 30 June 2025: Original application date for SMEs and micro-enterprises

Postponement (October 2024)

In October 2024, the European Commission proposed -- and the European Parliament and Council agreed -- to postpone the application dates by 12 months:

Note (April 2026): As of the date of this guide, the application date for large operators has passed (30 December 2025). SMEs have until 30 June 2026. The Commission has not signalled any further postponement.

Future milestones

• 30 June 2026: Application for micro and small enterprises
• 30 June 2028: Commission review of scope (possible extension to other ecosystems, financial institutions, additional commodities)
• Ongoing: Country benchmarking updates every two years (Article 29)

Who is affected?

Operators

An operator is any natural or legal person who, in the course of a commercial activity, places relevant commodities or products on the EU market or exports them (Article 2(15)). This includes:

• Importers who file customs declarations
• EU producers who place domestically produced relevant commodities on the market
• Exporters of relevant commodities from the EU

Operators bear the full due diligence obligation (Article 4): information collection, risk assessment, risk mitigation, and submission of a due diligence statement before placing products on the market.

Downstream operators (traders)

Traders are any persons in the supply chain other than the operator who, in the course of a commercial activity, make relevant products available on the EU market (Article 2(16)). They must:

• Verify that a due diligence statement exists for the products they handle
• Keep records of their suppliers and customers for five years
• If classified as "large" under accounting directives, conduct their own due diligence

See chapter 5 for the detailed obligations by actor type.

Authorised representatives

Non-EU operators may appoint an authorised representative established in the EU (Article 6) to fulfil due diligence obligations on their behalf. The authorised representative assumes the same legal liability as the operator.

Competent authorities

Each Member State designates one or more competent authorities responsible for enforcement (Article 14). In France, this role falls to the DGCCRF (Direction generale de la concurrence, de la consommation et de la repression des fraudes) in coordination with the DGDDI (customs).

The EUDR in the broader regulatory landscape

The EUDR does not exist in isolation. It forms part of a wider EU regulatory push on sustainability and supply chain responsibility:

Professionals handling imports of agricultural commodities should consider these regulations together when designing compliance systems. See chapter 7 for a preparation strategy addressing regulatory synergies.