EUDR update: the countdown to December 2026 has started

With less than six months remaining until the EUDR becomes applicable, organizations should assess their role in the supply chain and determine whether they will be responsible for EUDR compliance.

What is EUDR?

The EUDR is part of the European Green Deal and aims to ensure that certain products placed on or exported from the EU market are not linked to deforestation or forest degradation.

The regulation applies to products containing, fed with, or made using commodities such as cattle, cocoa, coffee, palm oil, rubber, soy, wood, and their derivatives. Before these products can be placed on the EU market, traded within the EU, or exported from the EU, companies must be able to demonstrate that the products are:

• Deforestation-free;
• Produced in accordance with the applicable laws of the country of production; and
• Covered by a Due Diligence Statement (DDS).

The most important change: the first-operator model

One of the most significant simplifications introduced by the EU is the shift towards a first-operator model.

Under the revised rules, the obligation to perform the full due diligence process and submit a Due Diligence Statement generally lies with the operator that first places the product on the EU market. Downstream operators can, under certain conditions, rely on the original Due Diligence Statement by maintaining the relevant DDS reference number and supplier/customer information.

As a result, companies should not assume that EUDR is someone else's responsibility. Importers, manufacturers, exporters and distributors may all have different obligations depending on their position in the supply chain.

Simplified regime for smaller operators

To reduce administrative burdens, the EU has introduced a special regime for certain micro and small primary operators.

In specific circumstances, these operators may use a simplified declaration mechanism instead of carrying out the full due diligence process.

What should companies do now?

For companies that qualify as the first operator, the EUDR requires much more than submitting a declaration. Organizations must establish processes capable of collecting supplier information, obtaining geolocation data, performing risk assessments, implementing risk mitigation measures and maintaining supporting documentation.

In practice, this requires a full control framework set-up. With the application date approaching rapidly, companies that have not yet started their preparations may face significant implementation challenges.

How can we help?

Forvis Mazars supports businesses with all aspects of EUDR compliance and our experts are ready identify your exposure, to guide you through the complex legislation and help you set-up a working control framework.