EUDR is Coming - Is Your Business Prepared?

May 06, 2025

Following a contentious rollout, the EU Deforestation Regulation (EUDR) is now set to take effect for many companies from December 30, 2025. Its main goal is to ensure products sold within the EU haven't contributed to deforestation or forest degradation anywhere in the world. This initiative is part of the EU's broader effort to combat greenhouse gas emissions and biodiversity loss caused by deforestation.

EUDR has faced criticism over its complexity and implementation challenges, ultimately resulting in the last-minute announcement of a 12-month delay in December 2024. However, the key requirements are now established, and a new cut-off date is fast approaching. As the Department of Agriculture, Food and the Marine (DAFM) steps up preparation for enforcement of EUDR in Ireland, it is now crucial to understand the implications for your business.

Who Needs to Comply?

Determining if EUDR applies to your business requires an understanding of the commodities and products derived from them that are within scope, as well as your role in the supply chain.

Relevant Products

Commodities: EUDR targets seven specific commodities known to be major drivers of global deforestation: cattle, cocoa, coffee, palm oil, rubber, soy, and wood.

Derived Products: The regulation covers not just the commodities but also many products made from them. These are listed by specific customs (CN) codes in Annex I of the regulation. It's important to check these codes carefully, as connections might not be obvious e.g. leather (from cattle), palm oil derivatives used in various industrial applications, and even books (using paper from wood).

Activities & Roles

EUDR applies to companies that engage in any of the below activities under two categories:

Operators: Anyone who places relevant products on the EU market for the first time or exports them outside of the customs union including:

Importing relevant products into the EU

Exporting them from the EU

Directly supplying them within the EU

Traders: Anyone in the supply chain other than the operator who supplies a relevant product for distribution, consumption or use on the EU market whether in return for payment or free of charge.

Key Dates

December 30, 2025: EUDR enforcement begins for large and medium-sized companies.

June 30, 2026: Small and micro-enterprises must comply by this date.

Transitional Rules: EUDR replaces the EU Timber Regulation (EUTR). Timber harvested before June 29, 2023, can still follow EUTR rules until December 31, 2028. Further exemptions are in place for other in-scope products placed on the market before the relevant EUDR application date.

Core Requirements for Products

For relevant products to be legally sold in or exported from the EU, they must meet three conditions:

Be Deforestation-Free: The commodities used must not originate from land deforested after December 31, 2020.

Be Legally Produced: Production must comply with the laws of the origin country, including land use rights, environmental protection, and human/labour rights.

Be Covered by a Due Diligence Statement (DDS): Before a product is placed on the market or exported, a DDS must be submitted electronically via a dedicated EUDR Information System (IS) to confirm that due diligence was performed.

The Due Diligence Process Explained

To declare "negligible risk”, Operators* and Non-SME Traders must follow a structured process:

Information Collection: Gather detailed data for each product batch including geolocation coordinates and proof of legal compliance. Downstream companies can reference the suppliers DDS but need to verify the data as they remain liable.

Risk Assessment: Analyse the collected information to assess the risk of the product not meeting EUDR standards.

Risk Mitigation: If the assessment shows a non-negligible risk, the Operator must take steps to reduce that risk to negligible before selling or exporting. If the risk can't be reduced, the product cannot enter the EU market or be exported.

Submit Due Diligence Statement (DDS): Once negligible risk is achieved, submit the DDS via the IS. This is in effect a declaration of compliance; detailed records of the due diligence measures must be kept for five years.

Note: *SMEs are subject to simplified due diligence procedures in certain circumstances.

Steps for Irish Businesses to Prepare

Build Organisational Knowledge: Review the materials listed in the Useful Resources section below, in collaboration with colleagues in procurement or supply chain roles.

Identify Exposure: Regularly assess your products and raw materials to determine whether they contain in-scope commodities or derivatives.

Understand Your Role: Determine your classification based on activities and business size, as this will define your specific compliance obligations under EUDR.

Map Your Supply Chains: Trace relevant products back to their origin, identifying all supply chain actors.

Develop Data Systems: Implement systems to collect, verify, and securely store the required information needed to demonstrate compliance.

Establish Risk Assessment Procedures: Design internal processes for assessing deforestation and legal compliance risks in line with EUDR criteria.

Engage with Suppliers: Clearly communicate your compliance expectations and data requirements.

Plan Risk Mitigation Measures: Define how your company will respond when a non-negligible risk is identified.

Train Staff on Due Diligence Statements (DDS): Ensure relevant teams understand the DDS process and are prepared to submit accurate statements through the EU’s central Information System.

Stay Informed: Monitor updates from DAFM and Ibec for further guidance related to EUDR implementation.

Consequences of Non-Compliance

Failure to comply means products cannot legally be sold in or exported from the EU. Penalties are designed to be "effective, proportionate and dissuasive" and can include:

Significant Fines: Potentially at least 4% of the company's annual EU turnover.

Confiscation: Seizure of non-compliant products and related revenue.

Market Bans: Temporary prohibition from trading relevant products in the EU.

Exclusion: Temporary bans (up to 12 months) from public contracts and funding.

Future Restrictions: Loss of access to simplified procedures.

Looking Ahead

EUDR fundamentally changes supply chain responsibility, demanding traceability of components down to the specific plot of land. Given the complexity and severe consequences of non-compliance, starting the preparation process by mapping supply chains, implementing internal systems and engaging early with suppliers is an urgent strategic priority.

Useful Resources

DAFM’s dedicated EUDR webpage features updates, a series of explanations including webinar recordings and a Frequently Asked Questions (FAQ) document.

The European Commission’s EUDR landing page for business, includes detailed guidance on the requirements and technical details of the Information System.