The EU’s Deforestation-free Regulation, (EUDR) has been in force since 29 June 2023 and will apply from 30 December 2024, when an array of new obligations will affect the supply chains of commodities and products in scope.

The EUDR’s overarching goal is to mitigate the impact of deforestation and forest degradation, with the aim to reduce greenhouse gas emissions and preserve biodiversity. Specifically, the regulation establishes strict due diligence requirements for companies that place certain commodities and products made from them on the European market or export them. The scope includes wood, beef, palm oil, soy, coffee, cocoa and rubber, but also a positive list of derivatives of these products, detailed in an annex of the regulation. The list of

products and commodities will be regularly updated and reviewed to account for changing deforestation patterns.

The EUDR will have significant international implications, especially on the trade of forest-related products. For any relevant goods or commodities to be placed on the EU market (or to be exported), these must be:

• Deforestation-free

• Produced in compliance with relevant legislation of country of production

• Covered by a due diligence statement

There are still a lot of issues to be covered in secondary legislation before its entry into force in December 2024, in the form of implementing acts that are currently being developed. Among other things, the functioning of the “register” information system and the high-risk countries categorisation (benchmark) need to be defined.

The European Commission is falling behind on this preparatory work, including on the preparation of guidance that aims to assist member states and industry with the implementation of the rules. Many calls have therefore been made to delay the application date, due to this uncertainty. For the time being, the European Commission has confirmed the delay of the benchmarking exercise, but not the delay of the rules as such.