ARTICLE
25 April 2025

Simplification Measures Announced For EUDR Implementation

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Arendt & Medernach

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On 15 April 2025, the EU Commission unveiled a series of simplification measures to facilitate the implementation of the EU Regulation on Deforestation-free Products, with the goal of reducing the compliance burden...
Luxembourg Corporate/Commercial Law

On 15 April 2025, the EU Commission unveiled a series of simplification measures to facilitate the implementation of the EU Regulation on Deforestation-free Products, with the goal of reducing the compliance burden for companies while preserving the Regulation's environmental goals.

Context

The EU Regulation on Deforestation-free Products (EUDR), which entered into force on 29 June 2023, is part of the EU's broader agenda to combat deforestation and forest degradation linked to the production and trade of key commodities. It sets strict requirements for companies placing products such as palm oil, cocoa, beef and timber on the EU market or exporting them from the EU. Under the EUDR, companies must demonstrate that these products have not been sourced from recently deforested lands and comply with local laws in their countries of origin.

While the Regulation officially applies to large and medium companies from 30 December 2025 and to micro and small enterprises from 30 June 2026, in October 2024 the EU Commission granted a one-year delay in implementation due to preparedness gaps observed among both EU and non-EU stakeholders.

Scope

The 15 April announcement focuses on three main areas:

  1. Updated guidance and FAQs:
    The revised documents now offer clearer explanations regarding traceability requirements, due diligence duties, and how the Regulation applies to composite products. It should be noted in particular that all components of such goods must be compliant, and that precise geolocation data is required for the production sites of commodities like palm oil, cocoa, and coffee.
  2. Public consultation on Annex I:
    A public consultation (open until 13 May 2025) has been launched to potentially revise Annex I of the Regulation. This could lead to an expansion or clarification of the product categories covered under the EUDR.
  3. Finalisation of country benchmarking:
    A benchmarking system, which is to be finalised by 30 June 2025, will classify countries or regions based on deforestation risk levels that are ranked as low, standard or high. This classification will directly impact the level of due diligence required by operators.

Key simplifications introduced

  • Due diligence statements can now be submitted annually instead of per shipment.
  • Existing due diligence statements can be reused when reimporting goods.
  • Authorised representatives may submit statements for company groups.
  • A simplified process allows companies to reference due diligence carried out by suppliers instead of duplicating due diligence efforts.

Implications for EU companies

The simplification package is expected to cut administrative burdens by approximately 30%, directly addressing industry concerns about complexity and cost. Larger companies in particular benefit from streamlined obligations, while SMEs are supported with extended timelines and fewer compliance burdens.

Next steps

  • Businesses are encouraged to review the updated guidance and FAQs.
  • Stakeholders can participate in the ongoing Annex I public consultation until 13 May.
  • Final benchmarking classifications are expected by 30 June 2025.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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