The EUDR countdown is on: are you ready?

There’s only six months to go until obligations under the EU’s Anti-Deforestation Regulation (EUDR) are set to take effect. From December 30, 2025, medium and large operators and traders will need to demonstrate full compliance with the new due diligence rules, designed to prevent companies from placing commodities linked with deforestation and forest degradation onto the EU market or exporting them from the EU. 

The stakes are high. Failure to comply could see companies exposed to financial penalties equivalent to 4% of turnover, restricted access to the EU market and significant reputational damage.   

But the road to implementation for EUDR so far has been a rocky one, with repeated delays, a lack of clarity and missing details.  

So, in the final few months before the regulation finally comes into effect, what are the latest developments that companies should be aware of?  

EUDR requirements: when, what, who  

Having first entered into force in June 2023 the EUDR was originally planned to take effect from the end of 2024 with many larger companies taking steps to prepare. 

But in December last year, a one-year implementation delay was agreed by the European Parliament.  

This grants larger operators and traders until December 30, 2025, and all other businesses until June 30, 2026, to comply.  

• • More than 50 employees
  • Annual turnover exceeding €10 million
  • Balance sheet total over €10 million

From the compliance date, any operator placing, making available or exporting one of seven commodities - cattle, cocoa, coffee, palm oil, rubber, soya and wood - or any derivatives from them on or from the EU market will need to ensure they are:  

• Deforestation-free: relevant materials are sourced from areas not affected by deforestation or forest degradation after December 31, 2020 

• Produced in accordance with the relevant legislation of the country of production. This includes compliance with that country’s land use rights, environmental protections, forest-related rules and labour rights, among others 
• Covered by a due diligence statement. NB. Businesses purchasing goods from operators – known as traders - will also be required to ensure that they have due diligence statements from suppliers.  

In signs that it plans to follow through on this updated timeline, in December 2024, the European Commission officially launched the portal via which due diligence statements will need to be submitted, the EUDR Information System.  

The latest guidance: key takeaways  

Though the EUDR’s core requirements remain intact, in April 2025, the Commission did release a series of documents designed to add further detail, clear up confusion and respond to more technical questions ahead of implementation.  

This included an updated guidance document and a fourth iteration of FAQs, as well as a draft Delegated Act (which remained open for consultation until May 13).   

Of the changes and clarifications introduced by these documents, there are a few key ones that food and drink businesses should ensure they’re aware of.   

These include:  

• The introduction of a simplified procedure by which downstream (non-SME) operators can verify upstream due diligence 

• Clarification on composite products, i.e., only the main relevant commodity in a composite product must undergo due diligence 

• Confirmation that there’s no legal obligation on ‘upstream’ operators to share geolocation data with downstream actors. Non-SME operators and traders, when referencing previous DDS, are not required to obtain geolocation data through the Information System or by other means. However, they may still wish to do so voluntarily, for their due diligence (e.g., if they wish to go beyond the minimum required for ascertaining) and are free to arrange information sharing through other channels, in line with data protection laws.

• A distinction between standalone packaging, ex. a pallet, which must be EUDR-compliant, and packaging material ‘used exclusively to support, protect or carry a product’ which falls outside the scope 

• Confirmation that Norway, Iceland, and Liechtenstein, though part of the European Economic Area (EEA), are considered as ‘third countries’ for the purposes of the regulation.  Northern Ireland however  should be considered an EU country in respect to EUDR due to the Northern Ireland Protocol.

• The exemption of product samples, as well as second-hand and used products.  

• Also excluded are materials such as user manuals, leaflets, and marketing materials when they accompany a product and correspondence.  

It’s worth familiarising yourself with all the updated guidance if you can, as well as attending the upcoming virtual training sessions being made available by the European Commission.  

Road to compliance: don’t delay 

The pushback to implementation of the EUDR has attracted hefty criticism, including from businesses that had implemented the required changes in line with the original deadline.  

But for the many companies that felt the regulation had lacked sufficient clarity and detail, the delay has afforded them valuable extra time to prepare.  

Now, with only six months until the regulation takes effect for large and medium companies (and only 12 months for SMEs) it’s critical that food and drink businesses make the most of this final bit of breathing space to get familiar with what’s required and have the processes in place to meet those requirements.  

This includes:  

• Full, robust supply chain mapping 
• Risk assessments of suppliers  
• Supplier engagement to ensure awareness and understanding of what’s required of them under EUDR 
• Centralised data collection systems to gather product name, quality, origin, supplier details, customer details, deforestation-free status and legislative compliant production 

Many of the tools created by Foods Connected can help to streamline this process, with our compliance management software designed to provide real-time visibility and transparency across your supplier network, including supplier lists, documentation, risk assessments, and compliance tracking.   

Whatever approach you use though, with hefty commercial consequences for non-compliance, don’t wait until the last minute.  

Instead, put in place robust traceability and data collection systems as early as possible to ensure there’s scope to take advantage of practise runs for due diligence documents and take into account any further updates.   

The countdown is on. 

Want to learn how to start mapping your supply chain? Download our free guide to learn more: