Deforestation Regulation Manager

Companies are required to comply with the EUDR if they import products into the EU that are linked to deforestation or forest degradation. The EUDR applies to specific raw materials such as wood, coffee beans, cocoa, palm oil, cotton, rubber, paper and certain products made from them. Companies must prove that these raw materials and products do not originate from deforested areas. The reporting obligation begins as soon as companies import these raw materials and products into the European market or export them from it. When exporting, the corresponding reference number of the due diligence statement must be provided. The regulation also applies to traders who offer these goods within the EU.   

The reporting requirements for companies are as follows:   

• Non-SME market participants: These companies must submit their first annual reports in accordance with Article 12(3) of the EUDR by 30 December 2025. The first report is therefore due for 2025 and must be published after 30 December 2025.    
• SMEs: The EUDR will only apply to these companies from 30 June 2026, meaning that they will also be subject to reporting requirements from this date.   
• Classification as an SME according to national transpositions and the status as of 31 December 2020 is decisive for the applicability of the EUDR. 

According to the EUDR, SMEs are only required to comply with the relevant requirements from 30 June 2026 onwards. However, in practice, large companies may request information on EUDR requirements from their suppliers, including SMEs, at an earlier date.     

Whether SMEs can refuse to disclose information depends on their contractual agreements with companies that are already subject to the EUDR. To avoid misunderstandings, it is advisable to make clear agreements in advance.    

As long as the SME can prove that the products in question were placed on the EU market before the EUDR came into force (29 June 2023), the raw materials and products are still EUDR-compliant. However, if the product was manufactured after 29 June 2023, the EUDR requirements must be observed. 

Future developments in the EUDR will be shaped by several dynamic factors. The EUDR is expected to evolve to meet the current challenges of global deforestation and climate change.  

Our EUDR software offers fully automated risk assessment that is updated daily, ensuring you are always up to date. In addition, our experts in compliance, ESG, and supply chain topics are closely familiar with the legislation and monitor developments on an ongoing basis. This enables us to quickly implement new developments and integrate them into the software. 

Companies affected by the EUDR are required to submit due diligence statements before selling or exporting any products. A statement may be made for several products or transactions if you can confirm that there is no or only a negligible risk for all products. You are also required to review your statements annually and keep them on file for five years from the date of submission to the EU information system TRACES.    

With the EUDR module from Check Your Value Chain, you benefit from a reliable process for risk analysis and automated submission of due diligence statements to TRACES, enabling you to ensure compliance with EUDR requirements and deadlines at all times.