The EU Regulation (EU) 2023/1115 on Deforestation-free products (“EUDR”) aims to combat global deforestation and forest degradation. On December 23, 2025, the current version of the EUDR was published in the Official Journal of the European Union, which, in addition to postponing the date of entry into force by one year, also contains several simplifications in the application of the regulation. Despite the simplifications, basic material requirements and, as a result, a number of corporate obligations remain in place.

Affected Products and Companies

The products and commodities relevant to the EUDR are explicitly listed in the annex to the EUDR along with their respective tariff codes. This includes the commodities wood, cocoa, coffee, oil palm, rubber, soy, and beef, as well as the listed products that contain, have been fed or have been made using relevant commodities.

In principle, all companies that place a product or commodity relevant under the EUDR on the market, make it available on the market, or export it from the Union are affected. Companies are divided into the categories “operators,” “downstream operators,” “traders,” and “micro or small primary operators”. Depending on their market position and role along the supply chain, different obligations and exemptions apply.

Operators place a relevant product on the Union market for the first time or export it from the Union market; primarily importing relevant raw materials or products. Downstream operators place on the market or export affected products made using relevant products all of which are already covered by a due diligence statement or by a simplified declaration (for example, when chocolate is produced from cocoa butter that has already been verified). Traders, on the other hand, merely resell relevant products that have already been imported into the Union market by an operator. The category of micro or small primary producers stems from that of market operators and refers to small undertakings or natural persons, established in a country classified as low risk, who place products they have grown, harvested, extracted, or bred themselves on the market.

Due Diligence Requirements

To comply with the requirements of the EUDR, companies must demonstrate that their products are “deforestation-free,” have been produced in accordance with relevant national legislation, and that a due diligence statement or a simplified declaration is in place regarding these characteristics. To meet these criteria, comprehensive information and data collection, risk analysis and assessment, risk mitigation measures, the implementation of a due diligence system, and the submission of the due diligence statement in the designated information system are required.

Exemptions and Simplifications

However, not all companies are affected to the same extent. One of the most significant changes resulting from the last-minute amendments at the end of 2025 provides relief for downstream operators and traders: These groups are no longer required to submit a due diligence statement. However, they must continue to ensure the traceability of products and record the relevant data internally for this purpose.

In addition, exemptions for SMEs already included in the earlier version of the EUDR remain in place, exempting them, among other things, from the public reporting requirement and the obligation to implement a due diligence system.

Conclusion

While the postponement and relaxation of the requirements under the Deforestation Regulation provide companies with some short-term relief, they still necessitate thorough preparation for the approaching effective date. Based on a sound legal assessment of one’s own market position and the resulting obligations, now is the right time to adapt purchasing and supply contracts, engage relevant stakeholders, and optimize internal processes as well as interfaces between affected departments.