What is EUDR: The EU Deforestation Regulation

In an increasingly sustainability-driven global market, companies must not only consider environmental impact but also consumer preferences for eco-conscious products. The European Union's Deforestation Regulation (EUDR) has emerged as a significant step in addressing deforestation, setting ambitious goals for deforestation-free supply chains.

This article is an essential resource for businesses of all sizes, including exporters and operators involved in the production, import, and sale of deforestation-linked products. It provides the overview of the regulation, including its implementation timeline, applicable product list, due diligence statement, and country risk classification.

What is EUDR? 

Deforestation, the clearance of forests for various purposes, has far-reaching environmental and social consequences. The EUDR, or European Union Deforestation Regulation, is a significant step taken by the European Union to address this global challenge. It aims to prevent deforestation and forest degradation by regulating the import of forest-risk commodities into EU Member States. 

EUDR’s Timeline for Implementation 

• May 2003: The EU adopted the Forest Law Enforcement, Governance and Trade (FLEGT) Action Plan 

• 2014: New York Declaration on Forests publishes a global timeline to slow and end forest loss during the UN Climate Summit 2014. 

• November 2021: The European Commission adopted a proposal for a regulation on deforestation-free products. 

• December 2022: The EU agreed on a Regulation for deforestation-free products to guarantee products EU citizens consume do not contribute to deforestation or forest degradation. 

• June 29, 2023: The European Parliament and Council formally adopted the EUDR. 

• December 30, 2024: EUDR goes into effect. (for non SMEs Traders and Operators - 18 months transition) 

• June 30, 2025: The EUDR becomes effective for micro and small exporters. Definitions for micro and small exporters have not been determined. (for SMEs Traders - 24 months transition) 

EUDR Applicable Category List 

• Cocoa & chocolate

• Coffee

• Palm oil

• Wood

• Soy

• Cattle & Beef

• Rubber

• Derived products such as leather, furniture, chocolate, tires, shoes, and more.

Example: Meat products, leather, chocolate, coffee, palm nuts, palm oil derivatives, glycerol, natural rubber products, soybeans, soy-bean flour and oil, fuel wood, wood products, pulp and paper, printed books)

Over the course of the next two years a review will be carried out, potentially adding additional products to this list.

EUDR Applicable Product List 

The regulation only applies to certain types of products. These products are identified by specific EU customs codes listed in Annex I. Any product with a customs code not on this list is generally exempt from the regulation. In other words, only products matching a code in Annex I need to comply with the regulation's requirements.

Relevant Commodity	Relevant Products
Cattle	Live cattle (0102 21, 0102 29) Meat of cattle, fresh or chilled (ex 0201) Meat of cattle, frozen (ex 0202) Edible offal of cattle, fresh or chilled (ex 0206 10) Edible cattle livers, frozen (ex 0206 22) Edible cattle offal (excluding tongues and livers), frozen (ex 0206 299 Other prepared or preserved meat, meat offal, blood, of cattle (ex 1602 50) Raw hides and skins of cattle (fresh, or salted, dried, limed, pickled or otherwise preserved, but not tanned, parchment-dressed or further prepared), whether or not dehaired or split (ex 4101) Tanned or crust hides and skins of cattle, without hair on, whether or not split, but not further prepared (ex 4104) Leather of cattle, further prepared after tanning or crusting, including parchment-dressed leather, without hair on, whether or not split, other than leather of heading 4114 (ex 4107)
Cocoa	Cocoa beans, whole or broken, raw or roasted (1801) Cocoa shells, husks, skins and other cocoa waste (1802) Cocoa paste, whether or not defatted (1803) Cocoa butter, fat and oil (1804) Cocoa powder, not containing added sugar or other sweetening matter (1805) Chocolate and other food preparations containing cocoa (1806)
Coffee	Coffee, whether or not roasted or decaffeinated; coffee husks and skins; coffee substitutes containing coffee in any proportion (0901)
Oil Palm	Palm nuts and kernels (1207 10) Palm oil and its fractions, whether or not refined, but not chemically modified (1511) Crude palm kernel and babassu oil and fractions thereof, whether or not refined, but not chemically modified (1513 21) Palm kernel and babassu oil and their fractions, whether or not refined, but not chemically modified (excluding crude oil) (1513 29) Oilcake and other solid residues of palm nuts or kernels, whether or not ground or in the form of pellets, resulting from the extraction of palm nut or kernel fats or oils (2306 60) Glycerol, with a purity of 95 % or more (calculated on the weight of the dry product) (ex 2905 45) Palmitic acid, stearic acid, their salts and esters (2915 70) Saturated acyclic monocarboxylic acids, their anhydrides, halides, peroxides and peroxyacids; their halogenated, sulphonated, nitrated or nitrosated derivatives (excluding formic acid, acetic acid, mono-, di- or trichloroacetic acids, propionic acid, butanoic acids, pentanoic acids, palmitic acid, stearic acid, their salts and esters, and acetic anhydride) (2915 90) Stearic acid, industrial (3823 11) Oleic acid, industrial (3823 12) Industrial monocarboxylic fatty acids; acid oils from refining (excluding stearic acid, oleic acid and tall oil fatty acids) (3823 19) Industrial fatty alcohols (3823 70)
Rubber	Natural rubber, balata, gutta-percha, guayule, chicle and similar natural gums, in primary forms or in plates, sheets or strip (4001) Compounded rubber, unvulcanised, in primary forms or in plates, sheets or strip (ex 4005) Unvulcanised rubber in other forms (e.g. rods, tubes and profile shapes) and articles (e.g. discs and rings) (ex 4006) Vulcanised rubber thread and cord (ex 4007) Plates, sheets, strips, rods and profile shapes, of vulcanised rubber other than hard rubber (ex 4008) Conveyer or transmission belts or belting, of vulcanised rubber (ex 4010) New pneumatic tyres, of rubber (ex 4011) Retreaded or used pneumatic tyres of rubber; solid or cushion tyres, tyre treads and tyre flaps, of rubber (ex 4012) Inner tubes, of rubber (ex 4013) Articles of apparel and clothing accessories (including gloves, mittens and mitts), for all purposes, of vulcanised rubber other than hard rubber (ex 4015) Other articles of vulcanised rubber other than hard rubber, not elsewhere specified in chapter 40 (ex 4016) Hard rubber (e.g. ebonite) in all forms including waste and scrap; articles of hard rubber (ex 4017)
Soya	Soya beans, whether or not broken (1201) Soya bean flour and meal (1208 10) Soya-bean oil and its fractions, whether or not refined, but not chemically modified (1507) Oilcake and other solid residues, whether or not ground or in the form of pellets, resulting from the extraction of soya-bean oil (2304)
Wood	Fuel wood, in logs, in billets, in twigs, in faggots or in similar forms; wood in chips or particles; sawdust and wood waste and scrap, whether or not agglomerated in logs, briquettes, pellets or similar forms (4401) Wood charcoal (including shell or nut charcoal), whether or not agglomerated (4402) Wood in the rough, whether or not stripped of bark or sapwood, or roughly squared (4403) Hoopwood; split poles; piles, pickets and stakes of wood, pointed but not sawn lengthwise; wooden sticks, roughly trimmed but not turned, bent or otherwise worked, suitable for the manufacture of walking sticks, umbrellas, tool handles or the like; chipwood and the like (4404) Wood wool; wood flour (4405) Railway or tramway sleepers (cross-ties) of wood (4406) Wood sawn or chipped lengthwise, sliced or peeled, whether or not planed, sanded or end-jointed, of a thickness exceeding 6 mm (4407) Sheets for veneering (including those obtained by slicing laminated wood), for plywood or for other similar laminated wood and other wood, sawn lengthwise, sliced or peeled, whether or not planed, sanded, spliced or end-jointed, of a thickness not exceeding 6 mm (4408) Wood (including strips and friezes for parquet flooring, not assembled) continuously shaped (tongued, grooved, rebated, chamfered, V-jointed, beaded, moulded, rounded or the like) along any of its edges, ends or faces, whether or not planed, sanded or end-jointed (4409) Particle board, oriented strand board (OSB) and similar board (for example, waferboard) of wood or other ligneous materials, whether or not agglomerated with resins or other organic binding substances (4410) Fibreboard of wood or other ligneous materials, whether or not bonded with resins or other organic substances (4411) Plywood, veneered panels and similar laminated wood (4412) Densified wood, in blocks, plates, strips or profile shapes (4413) Wooden frames for paintings, photographs, mirrors or similar objects (4414) Packing cases, boxes, crates, drums and similar packings, of wood; cable-drums of wood; pallets, box pallets and other load boards, of wood; pallet collars of wood (not including packing material used exclusively as packing material to support, protect or carry another product placed on the market) (4415) Casks, barrels, vats, tubs and other coopers’ products and parts thereof, of wood, including staves (4416) Tools, tool bodies, tool handles, broom or brush bodies and handles, of wood; boot or shoe lasts and trees, of wood (4417) Builders’ joinery and carpentry of wood, including cellular wood panels, assembled flooring panels, shingles and shakes (4418) Tableware and kitchenware, of wood (4419) Wood marquetry and inlaid wood; caskets and cases for jewellery or cutlery, and similar articles, of wood; statuettes and other ornaments, of wood; wooden articles of furniture not falling in Chapter 94 (4420) Other articles of wood (4421) Pulp and paper of Chapters 47 and 48 of the Combined Nomenclature, with the exception of bamboo-based and recovered (waste and scrap) products Printed books, newspapers, pictures and other products of the printing industry, manuscripts, typescripts and plans, of paper 8 (ex 49) Seats (other than those of heading 9402 ), whether or not convertible into beds, and parts thereof, of wood (ex 9401)    Wooden furniture, and parts thereof (9403 30 , 9403 40 , 9403 50 , 9403 60 and 9403 91) Prefabricated buildings of wood (9406 10)

EUDR Due Diligence Statement 

Company’s details: the products, the quantity, the geolocation of all plots of land where the commodities were produced - stating that there is no - or only a negligible - risk of non-compliance.  

When re-importing products previously exported from the EU and placing them under the 'release for free circulation' customs procedure, the same obligations apply as if the product were being placed on the market for the first time. Leveraging existing due diligence statements can assist operators in more seamlessly exercising due diligence during this process. 

EUDR Country Risk classification 

The Deforestation Regulation imposes on operators and traders an obligation to carry out due diligence to ensure that the products are deforestation-free, based on a Commission-run benchmark identifying countries (within and outside the EU) as low standard or high risk. 

The Commission will need to publish the list of the countries or parts thereof, that present a low or high risk no later than 30 December 2024. That list will then be reviewed and updated as often as necessary. 

This risk classification will be primarily based on: 

• The rate of deforestation 

• Forest degradation  

• Expansion of agricultural land for relevant commodities 

• Production trends of relevant commodities and products.  

• However, the Commission may also take into consideration the laws protecting human rights, the rights of indigenous peoples, local communities and other customary tenure rights holders 

The European Union Deforestation Regulation represents a vital step toward achieving sustainable sourcing practices as well as combating deforestation, mitigating climate change, and preserving biodiversity. While it holds the potential for substantial positive impacts, including emissions reduction and habitat protection, it also presents significant challenges for businesses in terms of compliance, transparency, and technology adoption. Achieving success under this regulation will require ongoing collaboration, innovation, and adaptation across the supply chain and regulatory landscape.  

Stay tuned for our upcoming articles, where Rockhill Asia delves deeper into the details of EUDR's due diligence process, identifies stakeholders who are concerned or impacted, and explores its broader implications.  

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