The EU Deforestation Regulation (EUDR) is a new law aimed at fighting deforestation by ensuring that certain commodities and products are deforestation-free and legally produced. This means that any operator or trader placing regulated products on the EU market or exporting from it must be able to prove the products are not linked to recent deforestation.

Traders are currently expected to comply with the EUDR from December 30, 2025 for large and medium companies and June 30, 2026 for small and micro enterprises. However, The European Parliament recently voted for a series of adjustments to the EUDR which would delay enforcement to December 30, 2026 for large and medium operators and June 30, 2027 for small and micro enterprises.

Traders play a crucial role in this system, bearing the responsibility to maintain and pass on traceability information across the supply chain. Their role is even more critical given how fragmented commodity markets are, often involving multiple layers of intermediaries before products reach the end market. In this guide, we break down what EUDR means for traders and outline practical steps from identifying your role to preparing for audits to help you meet the new requirements.

Who is considered a trader under EUDR?

Definition of traders according to EUDR

Under EUDR, a trader is defined as an SME or larger operator placing regulated products on the EU market for the first time. Any operator who buys or sells regulated products within the EU is considered a trader. This includes importers, distributors, wholesalers, and retailers. Even if you don't directly import products, if you are selling goods that have been produced with commodities covered by the EUDR, you are considered a trader and must comply with the regulation.

The key takeaway is that EUDR applies to a broad range of operators across the supply chain, not just importers. Understanding your role in the supply chain is critical to understanding your responsibilities under EUDR.

What are the responsibilities of traders?

EUDR imposes several key responsibilities on traders:

1. Due Diligence: Traders must conduct due diligence on supplied products to assess and mitigate the risk of placing deforestation-linked and illegal products on the market.
2. Traceability: Traders must maintain information on the name and address of suppliers and customers, as well as information on the location of the land where the regulated commodities were produced.
3. Documentation: Traders must keep detailed records of all transactions and communications related to regulated products. This information must be made available to authorities upon request.
4. Reporting: If a trader suspects that a product is linked to deforestation or illegal activity, they must report it to the relevant authorities.

Additionally, large operators (defined as those with net turnover exceeding EUR 150 million) are subject to stricter requirements under the EUDR, including regular audits and compliance certifications.

How should traders prepare for EUDR compliance?

Traders can take the following steps to prepare for EUDR compliance:

1. Understand Your Role: Determine whether you are a trader under EUDR and understand what responsibilities apply to your business.
2. Map Your Supply Chain: Identify all suppliers and understand the origin of your products. Create a comprehensive supply chain map that details where products are sourced and how they are processed.
3. Implement Due Diligence Procedures: Develop systems and processes to assess and mitigate deforestation risks. This may involve working with suppliers to obtain documentation and certifications that confirm products are deforestation-free.
4. Digitize Record Keeping: Set up digital systems to store and manage all documentation related to regulated products, including supplier contracts, certifications, and transaction records.
5. Train Your Team: Ensure that employees understand the requirements of the EUDR and their role in compliance. Conduct regular training sessions to keep the team informed about regulatory changes.
6. Prepare for Audits: Establish internal audit procedures to regularly review your compliance status and identify any gaps. Be prepared for external audits by authorities.

By taking these proactive steps, traders can ensure they are well-prepared to meet the EUDR requirements and avoid potential penalties for non-compliance.