The EU has adopted new dates for the application of the European Union Deforestation Regulation (EUDR)[1]. Companies now have one year to bring their supply chains into compliance, and Milena Kazanowska-Kędzierska and Aleksandra Pinkas summarise the main changes.
What are the new EUDR dates?
The date of application of the EUDR will be postponed to 30 December 2025 instead of 30 December 2024 as originally stated.
Entities operating as micro and small enterprises from 31 December 2020 will have even more time – until 30 June 2026 – before they are covered by the new rules.
The following products will be exceptions:[2]
Will the deadline for publishing the list of countries – producers of the relevant commodities causing deforestation – also change?
Yes, this deadline will also be extended.
As a reminder, the EUDR introduces a 3-tier system for assessing countries in terms of the risk of producing commodities that cause deforestation:
- High risk (where relevant deforestation-causing commodities are produced)
- Low risk (where production of such commodities is exceptional)
- Standard risk
By 30 June 2025, instead of 30 June 2024 as originally agreed, an implementing act will be published containing the list of low and high risk countries.
How can I use this extra time?
To prepare for the implementation of obligations under the Regulation. We strongly recommend that, despite the extended deadline from which the EUDR will apply, businesses involved in the supply chain of relevant commodities such as:
- cattle,
- cocoa,
- coffee,
- oil palm,
- rubber,
- soya, and
- wood
and the relevant deforestation-inducing products made from them, should start early to prepare for the implementation of a due diligence system and to assess the compliance of their trading partners.
And we can advise on how to prepare your business for the coming changes.
See also:
Eco Focus #4 on guidelines for relevant products in packaging.
Eco Focus #3 on the duty of due diligence.
Eco Focus #2 on the penalties and consequences for companies that do not comply with the rules and the system of checks.
Eco Focus #1 on the basic concepts and the list of commodities covered by the new rules.
Any questions? Contact us
[1] Regulation (EU) 2023/1115 of the European Parliament and of the Council of 31 May 2023 on the making available on the Union market and the export from the Union of certain commodities and products associated with deforestation and forest degradation and repealing Regulation (EU) No 995/2010 (OJ EU L 150 of 2023, as amended)
[2] In accordance with Annex to Regulation (EU) 995/2010 of the European Parliament and of the Council of 20 October 2010 laying down the obligations of operators who place timber and timber products on the market (OJ EU L of 2010, No 295, as amended)
[3] In accordance with the Corrigendum to Regulation (EU) 2023/1115 of the European Parliament and of the Council of 31 May 2023 on the making available on the Union market and the export from the Union of certain commodities and products associated with deforestation and forest degradation and repealing Regulation (EU) No 995/2010 (OJ EU L 150 of 2023) ST/12716/2024/INIT (OJ EU L 2024/90591 of 2024)
- the EUDR covers: packaging materials placed on the market as products themselves, containers that give the product its essential character: e.g. decorative gift boxes, and does not cover: packaging materials with goods inside, used exclusively to support, protect or carry other products, user manuals accompanying shipments, unless they are placed on the market as a product themselves.
