The consultation deadline for amending Annex I of the EUDR is 13 May 2025

PDF version available here: The consultation deadline for amending Annex I of the EUDR is 13 May 2025

The EUDR, or the Regulation (EU) 2023/1115 of the European Parliament and of the Council (EU Deforestation Regulation), aims to restrict the introduction into the EU market of products linked to deforestation and forest degradation and reduce the EU’s contribution to greenhouse gas emissions and global biodiversity loss.

The key obligations

1. Due diligence system

Businesses must implement systems to collect and store information to confirm that products have not contributed to deforestation and have been produced in accordance with the laws of the country of origin.

2. Geolocalisation of the source of products and commodities

It is mandatory to provide the exact geographical coordinates of each plot of land from which the commodities that the relevant product contains originate. In the case of compound products, all ingredients must be traceable.

3. Due diligence statement

Before placing products on the EU market or exporting them, businesses must submit a due diligence declaration through a dedicated information system. This declaration can cover multiple batches, but only for a specific period of time.

4. Risk assessment and minimisation

Regular assessment of the risk of potential deforestation in the supply chain is mandatory. Where risks are identified, minimisation measures such as additional audits or working with suppliers are required.

Businesses are also required to review and update their due diligence system annually and to report publicly on its performance.

Sanctions for non-compliance

• Fines of up to 4% of annual turnover in the EU
• Confiscation of goods and the profits of their sale
• Temporary ban on placing products on the EU market
• Exclusion from participation in public procurement and access to EU funds

Revision of Annex I to the EUDR

As part of the European Commission’s delegated regulation, Annex I to the EUDR has been updated, expanding the list of products affected by the regulation. The amendments aim to bring the regulation more in line with current market and environmental realities.

Support for entrepreneurs

In response to the challenges of implementing the EUDR, the European Commission has also published updated FAQ documents that clarify, among other things:

• geolocation and product traceability requirements;
• definitions of related products (relevant commodities) and forest degradation;
• risk assessment procedures and requirements for due diligence statements.

Deadlines for the application of the EUDR

• For large enterprises: from 30 December 2025
• For small and micro enterprises: from 30 June 2026

In addition, the classification of countries by risk level (low, standard, high) will be published by 30 June 2025.

Recommendations for businesses

• Early preparation

Start analysing the supply chain and identifying potential deforestation risks.

• Implement monitoring systems

Invest in technologies for traceability of commodities.

• Training and internal procedures

Prepare staff for their new responsibilities through training and the development of appropriate procedures.

• Cooperation with suppliers

Establish a dialogue with suppliers to ensure compliance with the EUDR.

• Regulation monitoring

Follow updates and guidelines published by the European Commission.

Conclusion

The EUDR introduces significant changes for businesses operating in the EU market. Early preparation and adaptation to the new requirements is key to avoiding sanctions and maintaining competitiveness.

If you have any questions or need support with the implementation of the EUDR, including monitoring of the EC updates and guidelines, please do not hesitate to contact our law firm.

Opinions submitted so far to Annex I can be followed via the link: EU rules to minimise deforestation & forest degradation – amendment of Annex I to the Deforestation Regulation