Objective of the EU Deforestation Regulation

The EUDR entered into force on 29 June 2023 as one of the EU’s latest trade‑restrictive instruments. It regulates the placing on the EU market and the export from the Union of certain commodities and products linked to deforestation and forest degradation. The Regulation introduces new obligations for affected companies and provides for significant sanctions in the event of non‑compliance. Its overarching objectives are to curb deforestation and forest degradation driven by EU consumption and production, reduce greenhouse‑gas emissions, and halt global biodiversity loss.

Relevant commodities and products

From early 2026, traders dealing in defined “relevant commodities” and in “relevant products” that contain, are fed with, or are made using such commodities must comply with new obligations with respect to goods and products produced after 29 June 2023.

“Relevant commodities” include, as defined by the EUDR, cattle, cocoa, coffee, oil palm, rubber, soy, and wood. “Relevant products” include, among others, beef and bovine hides, chocolate, natural and vulcanised or un‑vulcanised rubber, ebonite, charcoal, paper, printing products, furniture, prefabricated buildings of wood, chemically pure glycerine, palmitic acid, stearic acid and any animal fed with soy.

Persons in scope and core requirements

Obligations under the EUDR apply to:

• Operators (any natural or legal person who, in the course of a commercial activity, places relevant products on the market or exports them),
• Traders (any person in the supply chain other than the operator who, in the course of a commercial activity, makes relevant products available on the market),
• Operators established in third countries (i.e. outside the customs territory of the Union),
• SME operators, which are subject to lighter obligations.

For relevant commodities and products produced after 29 June 2023, their placing on the EU market, making available on the market, or exporting from the EU will, as of early 2027, only be possible if the following three cumulative requirement are met:

1. The goods are deforestation‑free (i.e. sourced from land on which no deforestation occurred after 31 December 2020).
2. Production must with comply with the laws of the country of production, including regulations on land use rights, human rights, environmental protection, sustainable forest management, labour rights, tax law, trade and customs and anti‑corruption.
3. A due‑diligence statement has been prepared and accompanies the goods placed on the market.

Adjustment of timelines

By decision of the European Parliament, the introduction of the EUDR obligations has been postponed again by one year. As a result, compliance is now required from 2027, rather than the original deadline of 30 December 2024. Given the complexity of these obligations and the potential severity of associated sanctions, it is strongly recommended that preparations begin as soon as possible.

EUDR sanctions

In the event of a breach of the EUDR, the competent authorities may impose a range of sanctions:

• prevent the placing on the market or export of relevant products,
• confiscate the goods and any revenues derived from the related transaction,
• order product recalls, donation of the products for charitable purposes or disposal in line with EU waste management legislation.

EUDR advisory: services by Andersen

Exporters and importers of relevant goods and products must exercise due diligence when establishing a framework based on the principle of due care. Designing and implementing the associated three-step procedural and control mechanism is a complex task, so specialist advisory support may be warranted. Although the EUDR applies only from 30 December 2026, affected companies should begin their preparations immediately.

The Andersen team supports all market participants in preparing smoothly for the new regime (EUDR Advisory), providing comprehensive assistance in designing the three‑step due‑diligence framework and related compliance processes.

Our articles on EUDR advisory (in Hungarian)

EUDR: áruelkobzás jár az erdőirtás elleni EU rendelet megsértéséért