The EU Deforestation Regulation (EUDR) is amended: what is the EUDR and what must companies do now?

After months of uncertainty, the EUDR has been amended by Regulation (EU) 2025/2650 (the “Amendments”). This briefing summarises the EUDR as amended.

What is the EUDR?

Adopted under the Green Deal, the EUDR aims to reduce the EU’s impact on deforestation, emissions and biodiversity loss. It regulates the placing on, making available on or exporting from the EU market of seven commodities – cattle, cocoa, coffee, oil palm, rubber, soya and wood (“relevant commodities”) – and products that contain, were fed with or were made using them (“relevant products”).

“Placing on the market” is the first making available of a relevant product in the EU; “making available” is any subsequent supply for distribution, consumption or use.

When does the EUDR begin to apply?

After the one-year delay introduced by the Amendments, it now applies from 30 December 2026 for medium and large operators, and 30 June 2027 for micro and small operators.

What are the relevant products?

For each commodity, the EUDR lists in-scope products (e.g., chocolate for cocoa, inner tubes for rubber, pallets for wood). The Amendments removed certain paper products, including printed books, newspapers, pictures and other printed matter.

What does the EUDR prohibit?

Relevant commodities and products may be placed on, made available on or exported from the EU market only if all three conditions are met:

• Deforestation-free: produced on land not subject to deforestation (and, for wood, without inducing forest degradation) after 31 December 2020.
• Legality in country of production: compliant with applicable laws on land use rights, environmental protection, labour and human rights, among others.
• Covered by a due diligence statement or simplified declaration, as required.

Does EUDR apply to all companies?

The EUDR applies to companies that place, make available on or export relevant commodities or products in the EU. Obligations vary by supply chain role and size. Following the Amendments, only operators must satisfy the full suite of EUDR obligations. Other categories of actor now have simplified or less onerous obligations.

Operators

First place relevant products on the EU market or export them (excluding downstream operators).

Downstream operators

Place or export relevant products made using relevant products already covered by a due diligence statement or simplified declaration.

Micro or small primary operators

Micro or small undertakings in ‘low-risk’ countries placing or exporting relevant products they have grown, harvested, obtained from or raised on relevant plots (or, for cattle, on establishments) in that country.

Traders

Supply-chain actors other than operators or downstream operators who makes relevant products available on the EU market.

SME (operators or traders)

Defined by EU accounting thresholds for balance sheet total, net turnover and average employees. See below, where on their balance sheet dates the entities do not exceed the limits of at least two of three of the metrics:

What must operators do?

Operators have two main obligations before placing products on the EU market or exporting them:

• Establish a system for and exercise due diligence covering information collection, risk assessment and, where needed, risk mitigation.
• Submit a due diligence statement via the EUDR information system, including country of production, geolocation of all plots and confirmation that due diligence found no, or only a negligible, risk of non-compliance.

Operators must not place or export products that are non-compliant, present more than a negligible risk of non-compliance or where due diligence and statement obligations were not fulfilled. Operators must also share with downstream operators and traders the reference numbers of due diligence statements or, if applicable, declaration identifiers for the products.

What are the information, risk assessment and risk mitigation requirements?

Operators must collect specified information, then assess risks and, if necessary, mitigate them.

Information requirements

Collect and retain information demonstrating compliance, including product description, country of production and geolocation of all plots where relevant commodities were produced.

Risk assessment

Verify and analyse the information to determine whether there is any risk of non-compliance. Products may only be placed or exported where there is no, or only a negligible, risk. Consider factors such as the country risk level, engagement with indigenous peoples, supply chain complexity and processing stage.

Risk mitigation

Where risk is more than negligible, adopt measures sufficient to reduce it to negligible before placing or exporting, such as collecting additional information or carrying out independent surveys or audits. Maintain proportionate policies, controls and procedures mitigate and manage risks of non-compliance, including model practices, reporting, record-keeping and an independent audit function.

Is there simplified due diligence?

Yes. Where, after assessing supply chain complexity, circumvention risk and ‘co‑mingling’ risk, operators have ascertained that the products were produced in ‘low-risk’ countries, operators need not conduct risk assessment or mitigation. They must, on request, provide documentation showing negligible risk of circumvention or mixing with unknown or higher‑risk origins.

What is the simplified regime for micro or small primary operators?

Micro or small primary operators must submit a one‑time simplified declaration in the EUDR information system before placing or exporting products; a declaration identifier will be assigned. However, where the required information already exists in an EU or Member State system, no declaration is needed. In addition, they may provide either geolocation data or postal addresses.

What must downstream operators and traders do?

Downstream operators and traders must hold specified information to place, make available or export relevant products; they do not conduct due diligence or submit statements. They must retain for five years: supplier and customer identity and contact details, and (where the supplier is an operator) the reference numbers of due diligence statements or declaration identifiers. They must also register in the EUDR information system before placing, making available or exporting products (not required for SME downstream operators or SME traders).

How will authorities check for compliance with EUDR?

Competent Authorities will conduct unannounced, risk‑based checks, considering factors such as commodities involved, supply chain length and complexity, adjacency of plots to forests and country risk level.

What are the consequences of non-compliance?

Importers must comply with the EUDR to complete customs formalities: non‑compliance poses significant business continuity risk. Where Competent Authorities identify products with high non‑compliance risk requiring immediate action, they may take interim measures, including seizure or suspension of placing, making available or export. Authorities may also require appropriate, proportionate corrective action within a specified period. Fines proportionate to environmental damage and product value may be imposed, up to at least 4% of total annual EU‑wide turnover.

What does this mean for companies?

Our advice to clients impacted by the Regulation is to take advantage of the one-year delay to implementation to invest now in new EUDR-aligned systems and processes. As described above, the obligations on operators are detailed, technical and onerous. It will take time to get new ways of working right and to embed them.

The delay also gives companies time to embed new EUDR-aligned systems for information gathering and risk assessment in a way that future proofs the business against the new EU Forced Labour Regulation (EUFLR), which will start to apply in 2027. The EUFLR will prohibit any company from importing or selling any products in the EU market that are tainted with forced labour at any point in the supply chain and will allow Member State authorities to seize, detain and destroy such products. The EUFLR does not mandate a particular type of forced labour due diligence but, in practice, the only way to spot and mitigate forced labour risks (and therefore to avoid the operational and reputational hit of an EUFLR investigation) is to ensure you are doing appropriate, risk-based, forced labour and wider human rights due diligence.

Business should avoid falling into the trap of taking a piecemeal and reactive approach to these new rules and, instead, invest in developing a strategic approach to due diligence that meets the needs of the business and its stakeholders and is appropriate to its size and resources – avoiding duplication of effort and cost in the process.

Need help?

For further information or tailored advice, please contact Kerry Stares or your usual Charles Russell Speechlys contact.