What is EUDR?
The EU Deforestation Regulation (EUDR) is a European law aimed at eliminating deforestation and forest degradation from global supply chains. It requires companies placing certain commodities on, or exported from, the EU market to prove that products are:
- Deforestation-free (no land cleared after 31 Dec 2020)
- Legally produced (compliant with local laws)
- Traceable to origin (farm/plantation-level geolocation)
Why Does It Matter?
Companies in scope of the legislation must carry out due diligence to demonstrate that their products are not sourced from deforested areas.
If you fail to do this, you will be at risk of fines, product bans and reputational damage.
It is still unclear as to whether EUDR will apply in Northern Ireland. We are expecting confirmation from Government imminently.
Who is in Scope?
- Operators: First to place products on the EU market or export them.
- Traders: Those who sell after products are already in the EU market.
- Applies to seven commodities and derived products:
- Cattle (beef, leather – derived products e.g. burgers, mince)
- Cocoa (derived products e.g. chocolate bars, confectionary)
- Coffee
- Palm oil
- Soy (supply chain watchout – animal feed)
- Rubber (synthetic versions OUT OF SCOPE)
- Wood (and paper products) (derived products e.g. books, toilet paper, furniture)
For the full list of commodities in scope, please see here.
Watch this video for a full explanation.
Key requirements:
· Due diligence statements (DDS) – Traders are required to submit a DDS to the European Commission's TRACES system, referencing any previous DDS statements from upstream operators.
o Due diligence – Traders are required to perform due diligence i.e. information gathering, risk assessment and risk mitigation (e.g. conducting surveys or field audits).
· Country Risk Ratings – the level of due diligence required depends on the risk rating of the commodity country of origin.
o The EU designates 140 countries as “low risk”, including all EU Member States. Four countries (Belarus, Myanmar, North Korea and Russia) are classified as “high risk”. All other countries are considered “standard risk”.
o Low Risk Countries = Simplified due diligence requirements (due diligence information required (e.g. geolocation data), no risk assessment and mitigation processes)
o Standard and High Risk Countries = Operator or Trader must go through the full due diligence process
o Products sourced from ‘high risk’ countries will be subject to closer scrutiny
Key Deadlines
Due to ongoing changes in the EU, the timelines are still uncertain and may be pushed back. Below we outline our expectations as to the EUDR timelines:
- Large & medium companies:
- CURRENT ENFORCEMENT DATE: 30 Dec 2025
- EXPECTED ENFORCEMENT DATE: Six-month grace period for enforcement (to 30 June 2026)
- Micro & small enterprises:
- CURRENT ENFORCEMENT DATE: 30 Jun 2026
- EXPECTED ENFORCEMENT DATE: 30 Dec 2026
BRC resources:
The BRC has been supporting members through a number of resources:
1. BRC Monthly EUDR Sprint Group – join our meeting to discuss and decipher EUDR. More info here.
2. BRC EUDR FAQs – read the latest BRC FAQs here (updated monthly)
3. BRC Standardised Supplier Questionnaire – find out more here
CEO-Level Priorities
1. Governance & Accountability: Assign board-level oversight for EUDR compliance. How can EUDR be incorporated into existing sustainability and risk frameworks?
2. Supplier Engagement: Ensure requirements are communicated early. Are you using the BRC’s standardised supplier questionnaire?
3. Scenario Planning: Prepare for Northern Ireland uncertainty and potential UK alignment issues. Is your EUDR lead attending the BRC Sprint Group?
Get in touch: For any EUDR queries, please contact Sophie De Salis, BRC Sustainability Policy Advisor.
