EUDR Regulation: what it is, deadlines and how to comply with due diligence

Introduction to the EUDR Regulation

These products may not be placed on the market, made available, or exported from the European Union unless they meet three conditions:

1. They are deforestation-free.
2. They have been produced in compliance with the legislation of the country of production.
3. They are covered by a due diligence statement (DDS) submitted to the EU information system.

Due diligence includes:

• Collection of information, data, and documentation.
• Risk assessment measures.
• Risk mitigation measures (unless the previous assessment shows negligible or no risk).

Who is subject to the EUDR?

Any natural or legal person who places, makes available, or exports relevant products in the EU. The regulation distinguishes between two categories of obliged entities:

• Operators
• Traders

The same entity may act as both at different stages of the supply chain, assuming different obligations.

Responsibilities depend on:

• The size of the operator or trader.
• The activity (placing on the market, making available, or exporting).
• Whether the products are subject to due diligence for the first time or come from those already covered.
• The level of associated risk.

Failure to submit due diligence prevents the marketing of products. Customs authorities will be responsible for controls, in cooperation with competent authorities under the EUDR. Non-compliance may lead to fines, prohibitions, or temporary exclusions.

One of the key instruments of the EUDR is the Due Diligence System (DDS): a framework of procedures, processes and measures designed to ensure that relevant products placed on the market, made available, or exported in the EU have not caused deforestation and have been produced in accordance with applicable legislation in the country of production. The DDS must be reviewed and updated periodically.

EUDR Compliance Deadlines

Although the regulation has been in force since 29 June 2023, there is a transitional period:

• Large and medium-sized companies: until 30 December 2025.
• Micro and small enterprises: until 30 June 2026.

Exception: timber products already regulated under the European Timber Regulation (EUTR).

In addition, it does not apply to relevant products produced before 30 June 2023 (except as provided in Article 37.3 for timber).

Benefits of complying with the EUDR

• Ensure compliance with mandatory regulation.
• Avoid sanctions that could block your business.
• Enhance corporate reputation.
• Optimise the supply chain.
• Complement other sustainability policies:
  • European Green Deal and Biodiversity Strategy: the EUDR is part of these EU policies.
  • Corporate Sustainability Due Diligence Directive (CSDDD): will require companies to assess risks to human rights and environmental impacts, including labour rights and pollution. The EUDR helps to make part of this journey and may require data to support the future directive.
  • CSRD Directive: facilitates integration of the EUDR into sustainability reporting.
  • EU climate policies: in the future, the EUDR may enable carbon footprint accounting by preventing deforestation and supporting adjustment mechanisms.
  • Global Biodiversity Framework (Kunming-Montreal): aligns land conservation with international commitments.

What do we do for your business?

At Hevalia, we help you adapt to the EUDR safely and efficiently:

• Initial assessment: identification of products subject to the EUDR and analysis of obligations (operator or trader).
• Due diligence consulting: prior to placing on the market or making available, assessing the appropriate procedure and the risk of deforestation or non-compliance with the legislation of the country of production.
• Consultancy on the design of the Due Diligence System (DDS): a framework of procedures and measures to ensure that relevant products placed or exported comply with the EUDR.
  • Information and documentation gathering, traceability and compliance.
  • Risk assessment based on objective data.
  • Risk mitigation measures, if necessary.
• Consultancy on the submission of the Due Diligence Statement (DDS) and obtaining a reference number.
• Consultancy on the creation of the Register of Due Diligence Statements.
• Consultancy on designing the Communication Protocol for due diligence statements to operators and traders in subsequent stages of the supply chain.
• Consultancy on drafting the annual public information report on due diligence actions.
• Consultancy on the maintenance and annual update of the DDS.
• Consultancy on auditing the due diligence system.
• Assistance in potential inspections and controls by competent authorities and customs under the EUDR.
• Continuous support.

Frequently Asked Questions about the EUDR Regulation