EUDR Enforcement: What Businesses Need to Know Now
On 21 October 2025, the European Commission proposed targeted amendments to the EU Deforestation Regulation (EUDR) and confirmed that the regulation will enter into force in January 2026. This announcement follows the 12-month delay granted in 2024 and comes amid ongoing discussions about further postponements and implementation challenges across the supply chain.
The proposed changes aim to streamline compliance and enable a more effective rollout of the regulation. Under the revised framework, the obligation to submit due diligence statements would rest solely with the first operator placing products on the EU market, relieving downstream operators and traders of the need to submit separate declarations. Micro and small primary operators located in low-risk countries would be exempt from recurring due diligence requirements and allowed instead to submit a single simplified declaration.
The Commission also proposes a phased implementation. Large and medium-sized enterprises would remain subject to the 30 December 2025 application date, followed by a six-month enforcement grace period. Micro and small companies, however, would benefit from a one-year postponement, with their obligations applying from 30 December 2026. These adjustments are intended to reduce administrative burden, avoid system congestion at go-live, and ensure that the regulation achieves its objective of creating deforestation-free supply chains in practice.
With the legislative proposal now under review by the European Parliament and the Council, companies should use this transition period to reassess their supply chain data, refine due diligence processes, and prepare for the upcoming reporting structure. At this stage, it appears highly likely that the Commission’s proposal will be adopted.
Understanding the EUDR – In Short
As a reminder, the EU Deforestation Regulation (EUDR) is one of the most far-reaching trade measures ever linked to environmental policy. It aims to ensure that certain goods entering or leaving the EU are not associated with deforestation or forest degradation anywhere in the world.
The regulation applies to seven key commodities: cattle, cocoa, coffee, palm oil, rubber, soy, and wood, and a wide range of derived products such as leather, chocolate, furniture, and printed paper.
In practice, any company placing these goods on the EU market must prove that they are both deforestation-free and legally produced. The EUDR establishes a new compliance model that merges trade, customs, and data governance obligations.
Businesses must trace the origin of their materials, collect geolocation data for production plots, verify the legality of sourcing, and ensure digital traceability across their supply chains. They must also maintain these records for at least five years, ready to be audited by authorities.
The UK Perspective:
For UK businesses, the EUDR’s impact is indirect but significant. While the regulation applies to EU importers and traders, it will inevitably affect UK exporters supplying goods or materials covered by the regulation.
Any UK exporter selling to EU buyers, whether directly or through intermediaries, will be expected to provide the traceability data and assurances those buyers need to complete their EUDR due-diligence statements. Many EU importers are already requesting such information as a condition of doing business.
The EUDR is also directly relevant for UK groups with subsidiaries or operations in the EU. Those entities, if they place covered products on the EU market, will themselves fall under the regulation’s operator obligations, including the duty to file due-diligence statements. For such groups, compliance is therefore both a strategic and operational necessity.
On 22 May 2025, the EU Commission confirmed the UK’s designation as a low-risk country, meaning that UK-origin goods will benefit from EUDR simplified due diligence, minimal compliance checks (1% instead of up to 9%), and streamlined procedures such as annual due diligence statements and the ability to reuse them for repeated shipments. These simplifications significantly reduce the administrative burden for UK timber and agricultural
exporters and strengthen the UK’s position in EU trade.
However, it is important to note that these advantages apply only to goods with UK origin. If products exported from the UK include or are derived from commodities sourced in higher-risk countries, such as Brazil or Indonesia, they can be treated as high-risk under the EUDR.
In such cases, EU importers must perform full due diligence, and UK exporters will need to provide comprehensive traceability and sourcing data from the original production sites to enable their EU partners to comply. A review of the EUDR’s impact across the entire supply chain is therefore essential to identify where exposure exists and to take timely action. The recent confirmation that the EUDR will enter into force on December 30, 2025 makes this action even more important.
For tailored guidance, contact our Advisory Team to assess your exposure and define a clear roadmap for compliance. Our experts support companies in both designing and operationalising robust EUDR policy frameworks to ensure readiness and prevent last-minute compliance risks.
