EU Deforestation Regulation: Roadmap to Compliance
Roadmap to Compliance: Deforestation, the conversion of forests to land used for agriculture or timber harvesting, is a major driver of global warming and biodiversity loss globally. Deforestation impacts more than the environment. It threatens indigenous livelihoods when communities lose forests, undermines global food security, and links directly to child and forced labour. In an attempt to combat these impacts, the EU adopted the EU Deforestation Regulation (EUDR). The Regulation aims to make Europe “deforestation-free” through prohibiting the sale of seven forest-risk commodities and their derivative products, unless they comply with requirements laid down in the EUDR. These requirements mean products must include a due diligence statement, be produced legally, and avoid land deforested after 2020.
Who does it apply to?
The regulation applies to companies operating with the seven forest risk commodities in scope of the Regulation, namely cattle, cocoa, coffee, palm oil, rubber, soy and wood, and their derivative products. Annex I of the Regulation lists derivative products such as meat, chocolate, rubber and leather goods, and pulp or paper products.
When does it come into effect?
The Regulation was adopted in 2023, with requirements initially to come into force in from December 2024. However, due to the complexity of the requirements of the Regulation, the EU pushed back the implementation dates to the beginning of 2026. This means that companies are currently grasping with the complexities of the regulation, in order to become compliant by the looming deadline.
What are the requirements?
The Regulation requires companies to submit a due diligence statement in the specified format, produce goods in line with the producer country’s legislation on eight legal aspects (e.g. human rights), and ensure products are deforestation-free under the EUDR. This means products must not contain or be made from commodities grown on land deforested or degraded after 31 December 2020. To prove compliance, companies must provide geolocation coordinates of sourcing locations together with the due diligence statement.
This means that to be fully compliant with the Regulation, extensive due diligence and risk management procedures must be in place, as well as methods of conducting the supplier engagement necessary for the collation of the information required for the submission of due diligence statements.
Requirements differ according to the value chain position of the given economic entity. Namely,
- Operators must comply with all requirements. They collect geolocation data, verify the legality of product production, and submit a due diligence statement confirming the product is deforestation-free.
- Traders must maintain and share DDS reference numbers and keep supplier and product records for at least 5 years. Non-SME traders must also fulfil due diligence obligations.
Documentation of the compliance process must be made available to national competent authorities upon request.
How can Clearstream help?
The requirements of the EUDR are vast and complex.
Goodbody Clearstream’s Responsible Sourcing Team are supporting companies get up to speed on the Regulation through:
- Scoping of commodities for applicability to the EUDR
- Training on the Regulation: its timelines, requirements, and suggested actions for compliance
- Providing step by step support for data gathering needed for the due diligence submission
- Build supplier engagement plans to collect all data required for EUDR compliance.
The EUDR is a sector specific example of a regulation based on due diligence and responsible sourcing. All sectors are adopting sustainable supply chain management, driven by regulations, customer demands, and growing calls for transparency.
This shift highlights the importance of monitoring your supply chain for environmental and social impacts and risks and implementing cross cutting strategies and policies for responsible sourcing to satisfy customer demand and stay ahead of the regulatory curve.
Note: On 23 September 2025, the EU Commission wrote to the EU Parliament expressing its intention to delaying the EUDR’s implementation by 1 year due to IT issues with its EUDR platform. Although this delay has not been signed into law at the time of writing, there is a possibility that delays and changes to the rules will be coming. Clearstream is closely monitoring and interpreting these developments to ensure accurate compliance information for our affected partners.
Reach out to Goodbody Clearstream team for support on responsible sourcing and sustainable supply chain management.
orla@goodbodyclearstream.ie colm@goodbodyclearstream.ie kate@goodbodyclearstream.ie