EU Deforestation Regulation
What is EUDR?
The EU Deforestation Regulation - EUDR - (Regulation (EU) 2023/1115) is an EU law designed to ensure that a defined set of raw commodities and related products placed on, or exported from, the EU market do not contribute to deforestation or forest degradation. Companies bringing goods covered by the regulation into the EU market must demonstrate that:
- Those products are deforestation-free, meaning they were not produced on land deforested or where forest was degraded after 31 December 2020; and
- They were produced in accordance with the relevant laws of the country of origin.
Obligations
The regulation identifies three roles with differentiated obligations along the supply chain: operators, downstream operators, and traders.
- Operators are required to carry out due diligence, tracing the products they place on, or export from, the EU market back to the plot of land where they were produced. They must ensure that deforestation and legality-of-production risks are negligible, and issue due diligence statements (DDS) through a dedicated EU information system (TRACES).
- First downstream operators / traders play a passive role and are required to keep DDS reference numbers for five years
- Subsequent downstream operators: keep business partner information only
Commodities in Scope
Seven raw commodities fall within scope of the regulation: cattle, cocoa, coffee, palm oil, rubber, soy, and wood, along with a wide range of derived products such as chocolate, furniture, tyres, paper, meat, and palm oil derivatives. Samples and products used for analysis, examination and testing are outside the scope of the Regulation; and there are targeted exemptions for specific categories of products including: waste, used and second-hand products; packing material; and products used in the manufacture of medicinal products.
When does it go in effect?
Following two rounds of delay, the regulation is now set to apply starting on the 30th of December, 2026 for large and medium-sized operators and traders, with an additional grace period until the 30th of June, 2027 for micro and small enterprises.
For the official and most current information, see the European Commission's regulation page.
Addressing EUDR
We have been identifying which products fall within the scope of the regulation by mapping ingredient composition and origin, for example distinguishing natural from synthetic sources, to build a definitive product list that will guide which suppliers we engage for the geolocation and production data collection as required by our due diligence processes. This background work helps lay the foundation for a compliance approach that is supported by accurate and verified data from day one.
We are implementing a leading digital tool provider to strengthen our supplier intelligence and assess deforestation risk across our supplier base globally. The tool connects directly to the EU's TRACES system and it gives us real time visibility of risks across our supply base enabling us to act quickly where it matters most.
Over the coming months, we are integrating our internal ERP and IT systems, embedding EUDR requirements into how we do business. Operationally, this work is being driven through a dedicated EUDR readiness project and steering committee, with clear milestones for the rollout set between August and November. Dedicated workstreams span both our business and IT functions, supporting organization readiness ahead of go-live.
Through this work, we are positioned to meet the EUDR with confidence, giving our customers and partners assurance that our supply chain is ready.
Our Commitment
We are committed to complying with the requirements of the Regulation (EU) 2023/1115 on deforestation-free products (EUDR) by December 30, 2026. We are working proactively, both internally and in close collaboration with our suppliers, to strengthen traceability and build the capabilities needed to be prepared when the regulation takes effect. This work reflects our broader commitment to responsible sourcing and sustainability across our business.
Disclaimer
This statement reflects current understanding of EUDR obligations. Processes may be updated as further clarification or regulatory changes emerge. Access to and use of sites connected via links take place at the viewer’s own risk.