EUDR

EUDR

EUROPEAN UNION DEFORESTATION REGULATION – DEFINE AND FULFILL YOUR RESPONSIBILITIES WITH US

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The EUDR is an EU regulation establishing obligations for entities trading in goods whose production involves a risk of deforestation or forest degradation. EUDR goods cover seven categories of goods. The European Commission has determined that these goods pose the greatest risk of deforestation during production.

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The regulation obliges entities that trade in these goods and products manufactured from these goods to take measures that include, among others:

• supply chain monitoring
• collection of geolocation data for production plots
• verifying that products have been manufactured in accordance with the laws of the country of manufacture (including human rights and environmental protection laws)

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I. WHO IS AFFECTED BY EUDR?

The regulation applies to all entities that

1. place on the EU market
2. make available on the EU market
3. export from the EU market

products that contain, have been fed with, or have been produced using EUDR commodities (note: cocoa, coffee, soy, palm oil, cattle, rubber, wood).

If you are unsure about your role in the market and your responsibilities, we invite you to take advantage of our services.

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II. OUR SERVICES

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What will you gain by working with ECHO?

• Consulting
• Compliance audit in the area of EUDR
• Outsourcing of responsibilities
• Determining the scope of responsibilities for your company
• Supply chain monitoring
• Obtaining the required EUDR product data from manufacturers
• Preparation of due diligence statements (DDS) and their disclosure in the EUDR IT system
• Assessment of the risk of non-compliance of your products with requirements
• Preparing recommendations for your company's due diligence system
• Conducting a due diligence system audit at least once a year in accordance with the requirements of the EUDR Regulation
• Supporting your company in its dealings with the relevant authority

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III. EUDR CALENDAR

The obligations for large and medium-sized enterprises will begin on December 30, 2025, and for small and micro enterprises on June 30, 2026.

The graphic below illustrates the original assumptions and current dates in the EUDR calendar.

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IV. EUDR PROCEDURE

The EUDR Regulation specifies the actions that a company must take in order to legally trade EUDR products. The end result of these actions is the submission of a due diligence statement for each product. This statement is necessary if the company wants to sell its products.

Below you will find the steps you need to take as a company subject to EUDR obligations. If you have any issues with any stage of the EUDR procedure, please contact us. We support companies at every stage of their journey towards EUDR compliance.

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First, the company is required to collect data on the EUDR products it intends to sell. At this stage, the entire supply chain must be traced, i.e., it is necessary to find out which entities were involved in trading the products before they reached the company and collect the required information from those entities. The end result of this stage is to have all the required information about the products, including:

• description, trade name, list of goods from which the final products were manufactured
• geographical coordinates of the plots of land where the goods used to make the final products were produced
• name, postal address, and email address of each company in the supply chain

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2. ASSESSMENT OF COLLECTED DATA IN TERMS OF RISK OF NON-COMPLIANCE WITH REQUIREMENTS

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At this stage, the company is required to evaluate the collected data to determine whether there is a risk that the products do not comply with the EUDR. The risk assessment takes into account, among other things, the following criteria:

• the prevalence of deforestation or forest degradation in producing countries
• complexity of supply chains
• the risk of mixing the company's products with products of unknown origin or produced in areas where deforestation or forest degradation occurs

If, after risk assessment, it turns out that the existing risk of non-compliance with the EUDR is greater than negligible, then the company must refrain from making its EUDR products available within the European Union and from exporting them from the Union.

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3. IMPLEMENTATION OF APPROPRIATE RISK MITIGATION MEASURES

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The implementation of appropriate and proportionate risk mitigation measures is necessary if the risk assessment identifies a risk of non-compliance that is greater than negligible. The company must ensure that the risk becomes negligible or zero by implementing measures such as:

• requiring suppliers or manufacturers to provide additional information, data, or documents
• conducting independent research and audits
• implementation of model risk management practices

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4. PREPARATION AND PUBLICATION OF DUE DILIGENCE STATEMENTS FOR EACH PRODUCT IN THE EUDR OPERATING SYSTEM

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If a company has exercised due diligence with regard to a given product, i.e., it has undergone the procedures described in steps 1-3, it should submit a due diligence statement for that product. Such a statement should be submitted in the IT system created for the purposes of the EUDR and should contain specific data, including:

• country of production and geolocation of all plots where the product was produced
• CN code, description, name, quantity of product purchased or sold

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5. PREPARATION AND IMPLEMENTATION OF THE DUE DILIGENCE SYSTEM

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The due diligence system includes the preparation and implementation of all procedures, instructions, actions, and documentation that lead to product compliance with EUDR requirements.

The company is also required to report and continuously monitor changes affecting the compliance of EUDR products with the requirements of the EUDR Regulation.

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V. LEGISLATION

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Please read:

1.  The content of Regulation (EU) 2023/1115 of the European Parliament and of the Council on deforestation and degradation: https://eur-lex.europa.eu/legal-content/PL/TXT/?uri=CELEX%3A32023R1115

https://eur-lex.europa.eu/legal-content/PL/TXT/?uri=CELEX%3A32023R1115

2. The content of the handbook published by the European Commission in English:

https://green-business.ec.europa.eu/publications/guidance-eu-deforestation-regulation_en