European Union Deforestation Regulation | What Has Changed in the Past Few Months
In late 2024, the European Union (EU) considered proposed amendments and a delay in implementing the European Union Deforestation Regulation (EUDR). As a result of this process, the EU postponed enforcement of the regulation from December 31st, 2024, until December 30th, 2025. The EU mandated simplification efforts for regulation implementation. As the Commission began working on this, they focused on five areas of implementation: the Information System/Registry of Due Diligence Statements, the Benchmarking System, Frequently Asked Questions, the Observatory Map, and Engagement with Industry.
Information System | Registry of Due Diligence Statements
Currently, a digital system is in place to enforce the EUDR. They have begun training the operators of the system and are currently completing 2 to 4 training sessions per week. These sessions are targeted to the operators that will directly interact with the system and will not be beneficial to companies who may be a part of the supply chain but will not ultimately be responsible for importing goods into European markets. For the month of March (2025), the EU has opened approximately 4,500 spaces for operators to take this digital database training. To obtain more information regarding the information system, please HERE.
Benchmarking System | Low, Standard, and High Risk
In accordance with Article 29 of the EUDR, the EU Commission will complete the benchmarking system by June 30th, 2025. The goal is to help authorities focus their enforcement resources on checks – 1% (low risk), 3% (standard risk), and 9% (high risk). Operators who source from low-risk countries will be subject to information collection only and will not need to complete an assessment or mitigate supply chain concerns. The Commission will engage with all countries that are, or are at risk of being, classified as high risk to reduce their level of risk. Risk will be assigned based on the criteria found in Article 29 of the EUDR regulation and can be found HERE.
Frequently Asked Questions (FAQs)
Regulators are also working to add 14 new questions to the existing 120 questions in the FAQ document. These additional questions attempt to clarify/simplify issues around frequency of submissions, forest degradation concerns, and questions about plantations. For instance, the Commission clarified that operators can file one statement to cover shipments for a year. Additional clarifications include answers for products containing multiple commodities, frequency of DDS submission, commercial activities, and forest degradation. The new FAQ is expected to be released in April.
Observatory
The Observatory map has been built for monitoring purposes to support the implementation of the regulation and provides land cover maps on the cut-off data. The map is a tool designed to help companies ensure compliance and can be used to inform the risk assessment for operators/traders and the EU Competent Authorities.
Please click HERE to access the map.
Engagement
In 2024, the EU Commission held 382 meetings with countries, companies, universities and think tanks, international organizations, NGOs, and trade associations. They have committed to continuing this type of engagement in 2025 to facilitate the implementation of the EUDR.
Conclusion:
Additional concerns remain around the implementation of the EUDR, including concerns about multiple sources of material in one commodity. The multiple source commodity must still be traced back to source of origin, and multiple origins can be identified for the outputs. There are still some concerns around how commercially sensitive information will be safeguarded as the suppliers may be required to provide this information to the operators/importers who are placing goods on the European Markets in order to comply with the EUDR. Unfortunately, the Commission has reiterated that only operators are allowed to file information in the EU database and that it is the responsibility of the operator to complete the due diligence, including obtaining the geo-location of the origin of the material.
