The European Deforestation Regulation (EUDR) explained
By 30 December 2025, the implementation of the EU Deforestation Regulation (EUDR) should be complete. The new regulation combats global deforestation and forest degradation by banning high-risk products from the European market. Focus is placed on certain commodities and derived products often associated with deforestation and forest degradation: palm oil, soya, coffee, cocoa, timber, rubber and cattle. What exactly does the EUDR entail and how does it affect Belgian companies? You can read all about it here.
Deforestation is a major threat to biodiversity and our climate. A significant proportion of global deforestation is caused by the production of food products going to industrialized regions like Europe. The EUDR wants to put a stop to this through strict regulation of a number of critical products.
The EUDR focuses on seven commodities whose production often leads to deforestation: cocoa, coffee, palm oil, soya, timber, rubber and cattle. Derived products containing or made with these raw materials are also listed (in Annex I). These include, for example, leather, chocolate and furniture. The EUDR now prohibits companies from placing all these critical raw materials on the EU market or exporting them from the EU unless they meet all the following conditions:
they are deforestation-free;
they are produced according to the laws of the producing country;
they are accompanied by a due diligence statement.
The requirements apply to anyone who imports raw materials into Europe and sells them on the European market. All market participants and traders other than SMEs must communicate annually and publicly (including online) about their due diligence processes and measures taken to comply with the obligations. A compliance officer must be appointed at management level and an independent auditor must be in charge of verification, controls and procedures. Finally, companies are subject to border controls and risk significant penalties if they do not follow the rules. EU member states provide the national interpretation of those sanctions.
Traceability and due diligence
In order to prove that the goods in question do not contribute to deforestation or forest degradation, traceability is indispensable. Any volume of EUDR products entering Europe must be 100% traceable back to the area of origin. Such a strict requirement makes the EUDR a real gamechanger: all farms in EUDR sectors, from small cocoa farmers to large palm plantations, must be mapped with GPS systems. The origin of all those volumes is then tracked at all steps along the supply chain.
This traceability is strongly linked to the principle of due diligence: a comprehensive risk exercise that analyses where along the chain malpractice might be happening. Based on that knowledge, you can take appropriate measures as a company. Due diligence is also required in other EU legislation, such as the CSDDD and CSRD. The EUDR itself distinguishes the following 3 steps in due diligence, after which you submit a due diligence statement to a central information system.
Due diligence steps within the EUDR:
1. Gather information on conformity
You must obtain all relevant information, and communicate it in your due diligence statement. This includes the raw material or product in question, quantity, supplier, country of production, proof of legal harvest, and so on. An important requirement is the geographical coordinates of the plots where the raw material was produced. If you cannot provide the required information in your due diligence statement, you should refrain from marketing the product. For those who were wondering: you have to retain such information for five years.
2. Analyse and assess risk
You then evaluate the risks linked to the raw material/product in question. This risk analysis should be repeated at least once a year. Everything revolves around the risk classification of the country or region where your raw material was produced. To have the risks assessed correctly and uniformly, the Commission is preparing a comparative list, in which all producing countries are ranked according to the risk of deforestation and forest degradation. There will be three levels: high, standard and low. While the list (which must be published by 30 December 2025) is pending, all countries will be classified as ‘standard’. If all of your commodities come from areas assigned as low risk, simplified due diligence requirements will apply.
3. Measures to minimize the risk
In the third step, you take appropriate and proportionate risk mitigation measures, if the risk analysis showed this to be necessary. These may include, for example, requesting additional information, conducting (independent) audits, providing support to your suppliers, or establishing concrete initiatives to protect forests. The procedures and measures to reduce risks should be reviewed at least once a year.
Deep dive: the due diligence statement
The due diligence statement is a declaration you have to submit to customs prior to importing to or exporting from the EU. It contains the geolocation coordinates of all plots of land from which the product comes or where it is produced, alongside other relevant information, such as the goods in question and their volumes, location and type of activity, etc.
The Commission will set up an information system to collect all due diligence statements. A unique reference number will be attached to each upload, which in turn will have to be made available to customs and often also to the buyers of your product. The entire system must be in place by 30 December 2025. The deadline is tight because by then the Commission must also classify countries and regions according to their risk of deforestation.
Do you have questions about the due diligence research or statement? Our experts are at your service. Contact us at mail@pantarein.be
What is the EUDR timeline?
In this timeline, you will find the key milestones of the EUDR:
31 December 2020
Cut-off date
Commodities under the EUDR must not come from land that has been deforested after this date, or have contributed to deforestation after this date.
23 June 2023
EUDR published in the Official Journal of the EU.
29 June 2023
EUDR comes into effect and start of transition period.
30 months implementation time for large market players, 36 months for small market players.
3 May 2024
First steps to implement the EUDR in Belgian law: product standards law amended, along with other laws around the economic legal framework.
30 December 2025
Full implementation of the EUDR required.
End of transition period for large market players.
Information system for due diligence statements in place.
Risk assessment system in place.
30 June 2026
End of transition period for small market players.
31 December 2027
Final end of EUTR, regulation around timber and timber products.
Until that date, the EUTR will remain in force for timber harvested before 29 June 2023 and marketed from 30 April 2024.
These are the rules for SMEs
SMEs using/marketing one or more products to which the EUDR applies should also be aware of their obligations. Companies meeting fewer than two of the following criteria are categorized as SMEs:
Balance sheet up to €25 million
Net turnover up to €50 million
Average number of employees up to 250
The rules for SMEs are slightly less strict than for large market players. SMEs do not have to carry out due diligence, but they are required to collect contact details of both their own suppliers and the companies they supply to for five years. They also have to keep the reference numbers of their suppliers’ due diligence statements.
SMEs will also be given an additional six months to implement the requirements of the EUDR within their organization, i.e. until 30 June 2026.
What is the situation in Belgium?
In Belgium, the FPS Health is responsible for enforcing the EUDR. Federal inspectors will carry out the investigations. In addition, Belgium, like other EU member states, must report annually to the European Commission on control plans, the results of controls, and penalties imposed. Meanwhile, Belgium is already incorporating the EUDR into national law. The Product Standards Act was amended as recently as May 2024. It already stipulates that products seized under the EUDR, with the exception of cattle, may be sold or donated for research purposes or in the public interest through an administrative measure. If they have little value for public sale or donation, they may also be destroyed. A few things are also known about the penalties: a prison sentence can range from 8 days to 3 years, and a fine from €160 to €4,000,000. A criminal court may also impose additional penalties, such as the temporary closure of the establishment or a product recall.
Do you have any questions about the EUDR? Pantarein is here to help. Contact us at mail@pantarein.be
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