Disclaimer: New EUDR developments - December 2025
In November 2025, the European Parliament and Council backed key changes to the EU Deforestation Regulation (EUDR), including a 12‑month enforcement delay and simplified obligations based on company size and supply chain role.
Key changes proposed:
- New enforcement timeline: 30 December 2026 for large/medium operators, 30 June 2027 for small/micro operators
- Simplified DDS: One-time declarations for small and micro primary producers
- Narrowed scope: Most downstream actors and non‑SME traders would no longer need to submit DDSs
- New DDS requirement: Estimated annual quantity of regulated products must be included
These updates are not yet legally binding. A final text will be confirmed through trilogue negotiations and formal publication in the EU’s Official Journal. Until then, the current EUDR regulation and deadlines remain in force.
We continue to monitor developments and will update all guidance as the final law is adopted.
What is the scope of the EU Deforestation Regulation?
The EU Deforestation Regulation (EUDR) covers several commodities that are considered to be major drivers of deforestation. The regulation applies to the following products and their derivatives:
- Beef and beef products
- Cocoa and cocoa products
- Coffee and coffee products
- Oil palm and palm oil products
- Soy and soy products
- Wood and wood products (with some exceptions)
- Rubber and rubber products
- Chocolate and other cocoa-based products
Products containing or made from these commodities are also covered, so companies in the processed food, cosmetics, and textiles sectors, among others, may be affected. However, there are some exemptions, such as products made from sustainably managed forests.
Penalties for non-compliance
The EUDR includes strict penalties for companies that fail to comply with its requirements. Penalties can include:
- Fines: Companies can face fines of up to 4% of annual turnover for serious breaches and up to 2% for minor breaches.
- Seizure of Products: Non-compliant products can be seized and destroyed at the expense of the company.
- Bans from Market: Companies that repeatedly fail to comply may be temporarily or permanently banned from the EU market.
- Reputational Damage: Non-compliance can lead to significant damage to a company's reputation and brand value.
Given the strict penalties, it is critical for traders to understand their responsibilities under the EUDR and take proactive steps to ensure compliance.
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