The EU Deforestation Regulation (EUDR), adopted in 2023, has undergone several significant updates to its timeline, compliance requirements, and risk assessment framework throughout late 2024 and 2025.
It aims to reduce the EU’s contribution to global deforestation and forest degradation by ensuring that certain products—such as cattle, cocoa, coffee, palm oil, rubber, soy, timber, and their derivatives—placed on or exported from the EU market are deforestation-free and produced legally. Geolocation data (i.e. traceability to a plot of land) in the country of production must be collected to ensure that commodities produced on deforested land after 31 December 2020, untraceable products or those that do not comply with the rules cannot be placed on the EU market or exported.
Compliant products must be stored separately to non-compliant ones.
It is also another mechanism for reducing carbon emissions caused by EU consumption of these commodities.
To help you understand these changes, we’ve provided a comprehensive overview of the regulation and the various updates it has gone through.
Extended deadlines and transitional periods
In December 2024, the European Parliament and Council agreed to delay the application of the EUDR by one year, giving businesses and trading partners more time to prepare. Large and medium-sized operators must now comply from 30 December 2025, while micro and small enterprises have until 30 June 2026. This postponement was introduced to allow companies and producers, particularly in third countries, to develop adequate due diligence systems.
Digital systems and simplified compliance
To support implementation, the European Commission launched the EUDR Information System in December 2024, providing a centralised platform for submitting due diligence statements. Alongside the live platform, a training version was released to help businesses and authorities familiarise themselves with the system. Over 2,500 operators and dozens of national authority representatives have engaged in this training.
In April 2025, the Commission introduced measures to reduce the administrative burden of compliance by around 30%. These include allowing companies to submit annual due diligence statements rather than per-shipment filings, permitting the reuse of statements for re-imported goods by large companies, enabling group representatives to file on behalf of company groups, and lowering obligations for downstream operators, who may only need to collect supplier reference numbers.
Country risk classification and scrutiny
A key feature of the EUDR is its benchmarking system, published in May 2025, which classifies countries as high, standard, or low risk based on deforestation levels and governance standards. The classification affects inspection rates: 9% for high-risk, 3% for standard, and 1% for low-risk origins. So far, only Belarus, Myanmar, North Korea, and Russia have been designated as “high risk,” while major exporters like Brazil and Indonesia remain “standard risk,” and the United States is considered “low risk.”
However, the European Parliament raised concerns about the methodology in July 2025, criticising the use of outdated (pre-2020) data, lack of regional granularity, and the absence of a dynamic reassessment mechanism. Lawmakers called for a more transparent system, potentially introducing a “no-risk” category and allowing countries to shift between risk levels as conditions improve.
The data for the risk assessment is from the Food and Agriculture Organisation (“FAO) 2020, with the next assessment from the FAO due in October 2025. It would seem sensible, therefore, to wait for the implementation of the EUDR risk assessment criteria to be based on the 2025 data, rather than rush through rules that are base don data that may be 5 years out of date.
Regulatory streamlining and concerns
While industry groups have welcomed this move to reduce regulatory complexity, some environmental advocates warn that ongoing delays and simplifications could weaken the regulation’s effectiveness in combating global deforestation.
The recent changes to the EUDR could be seen as a double-edged sword for its core goals of halting deforestation and promoting sustainable trade.
On one hand, delaying compliance by a year (to late 2025 for most operators) and introducing simplified reporting—such as annual rather than per-shipment due diligence statements and lower obligations for downstream actors—gives businesses, especially smaller ones and producers in developing countries, more time and flexibility to build the systems needed to comply. This could lead to better long-term compliance and data accuracy, avoiding rushed, low-quality reporting.
On the other hand, these delays and simplifications risk slowing the regulation’s immediate environmental impact. Postponements mean that deforestation-linked products could continue entering the EU market for another year or more, and critics argue that lighter administrative burdens could weaken enforcement and traceability, especially if companies exploit streamlined rules.
The country risk classification system has also been contentious: while it focuses enforcement on high-risk countries, lawmakers warn that its reliance on outdated data and limited regional detail could misclassify nations and undermine the regulation’s credibility, potentially letting deforestation slip through the cracks.
Staying on top of these shifting rules isn’t just about avoiding fines—it’s about keeping products in the EU market, protecting supply chains, and staying competitive. With timelines, reporting standards, and risk classifications still evolving, businesses that track these updates can plan ahead, safeguard their reputation, and turn compliance into a market advantage, while those who fall behind risk costly penalties and lost opportunities.
Whilst EUDR does not impose a tax on importers of the products, it does put an administrative burden on businesses to comply. This may lead to shortages of some products in the EU because the goods cannot be geolocated or do not otherwise comply with EUDR.
It is a laudable concept, but if businesses find it too difficult to comply with, they may turn their backs on EU markets.
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