The EU Regulation on Deforestation-free products (“EUDR“), which entered into force on 29 June 2023, will apply on 30 december 2025 for operators and large enterprises (non-SMEs) and on 30 June 2026 for micro, small and medium-sized enterprises (SMEs), repealing the EU Timber Regulation (“EUTR”). However, the EUTR remains in force until 31 December 2028 for timber (products) that were produced before 29 June 2023 (the entry into force of the EUDR) and placed on the market from 30 December 2025. For timber products produced after 29 June 2023, the EUTR will be repealed when the EUDR enters into application.
The Netherlands Food and Consumer Product Safety Authority (NVWA) has stated in its 2025 annual plan that combating deforestation will be one of its priorities. Non-compliance with the EUDR may result in exclusion from tenders and/or subsidies for up to 12 months, confiscation of non-compliant products, administrative fines, or even criminal investigations into companies and their directors. For companies in the Netherlands, criminal fines can even reach up to 10% of their annual turnover, emphasising the importance of compliance.
The EUDR requires operators and traders to conduct thorough supply chain due diligence for deforestation-linked products, with responsibilities varying depending on company size, supply chain position and a country’s risk classification. Ongoing discussions about the risk classifications, including a potential "no risk" category, have created some uncertainty. Until a definitive outcome is reached, companies are advised to introduce and maintain due diligence procedures for all sourcing countries.
The overview below can give companies a clear understanding of the changes ahead.
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Download the overview
Download the overview 'Navigating the EUDR: a guide to the EU's Deforestation-free products Regulation' here.
EU discussions on country benchmarking
On 22 May 2025, the European Commission adopted Regulation 2025/1093 establishing a country classification system based on deforestation risk levels with corresponding due diligence requirements. However, the European Parliament rejected this proposed classification list, raising concerns about the methodology and data quality. Additionally, the country classification list has prompted discussions on introducing a "no risk" category, which would exempt certain countries from standard EUDR requirements. To date, a revised classification list has not been published, leaving the regulatory framework uncertain. As a result, companies should continue implementing comprehensive due diligence procedures for all sourcing countries, regardless of anticipated risk classifications.
Conclusion
The EUDR represents a significant expansion of the EU's regulatory framework, extending beyond the EUTR to cover a wide range of relevant products linked to deforestation. These new obligations may appear complex. Careful understanding and implementation of the requirements is essential to ensure compliance and effectively address the far-reaching implications of the EUDR.
Should you have any questions, our Corporate Crime & Business Integrity team is available to provide further guidance.
