The European Union has adopted Regulation (EU) 2023/1115 on deforestation-free products (EUDR) to combat global deforestation and forest degradation. Its main objective is to ensure that relevant commodities and products placed on or exported from the Union market are not associated with deforestation. The European Commission has issued guidance document, which is not legally binding, but provides important information and clarifications for operators, traders and national authorities when implementing the EUDR.

Key concepts and scope of the EUDR The EUDR Regulation focuses on goods that are "placed on the market", "made available to the market" within the Union or "exported" from it.

• Market positioning occurs when the relevant commodity or product is first made available on the Union market in the course of a commercial activity.
• Making available to the market means the supply of the relevant product on the Union market for distribution, consumption or use, including in the course of a commercial activity.
• Export concerns the customs export procedure for Union goods to be exported from the customs territory of the Union.

Operators is any natural or legal person who places the relevant products on the market or exports them in the course of a commercial activity. It is important that the EUDR only applies to products manufactured after 29 June 2023. Most obligations for large and medium-sized enterprises started to apply from 30 December 2025, while for micro and small enterprises the deadline is postponed to 30 June 2026.

Due diligence obligations A key element of the EUDR is due diligence (due diligence) that operators must carry out before placing products on the market or exporting them. The due diligence process includes three main steps:

1. Information collection: Operators must collect detailed information about relevant products and their suppliers, including the geolocation of all land where the commodities were produced and the date of production.
2. Risk assessment: The information collected must be analysed to assess the risk that the products do not comply with the requirements of the regulation. Criteria such as the country of manufacture, the complexity of the supply chain and potential involvement in illegal practices are taken into account.
3. Risk mitigation: If the risk assessment does not reveal only negligible risk non-compliance with the Regulation, the operator must take effective measures to mitigate this risk. If the risk is considered to be non-negligible, the product must not be placed on the market or exported.

The role of traders and compliance Traders who are not SMEs, have the same due diligence obligations as operators. They must ensure that due diligence has been carried out in the supply chain before them. Traders who are SMEs, are not required to carry out due diligence, but are required to collect and store information about their suppliers and the reference numbers of due diligence statements and provide them to competent authorities upon request.

Relevant products must not only be without deforestation (i.e. produced on land that has not been deforested after 31 December 2020), but must also be manufactured in accordance with the relevant legislation of the country of manufactureThese laws may include land rights, environmental protection, forestry regulations and human rights. In the case of composite products (e.g. a wood product containing multiple wood components or chocolate with cocoa and palm oil), due diligence must apply to all relevant commodities and products from which the final product is made. If any of the identified parts of the product are associated with deforestation, the entire product must not be placed on the market or exported.

Certifications and verification schemes Third-party certification and verification schemes can be a useful tool to support risk assessment as they provide additional information on compliance with the Regulation. However, it is crucial that do not replace the direct responsibility of the operator for exercising due diligence. The operator remains fully responsible for compliance with the EUDR requirements.

This comprehensive framework, explained in detail in the guidance document, is intended to help all stakeholders meet their obligations, thereby contributing to global efforts to protect forests and mitigate climate change. JRi