EUDR Overview and Objectives
The regulation in one sentence
Regulation (EU) 2023/1115 prohibits the placing on the EU market, or the export from the EU, of seven categories of commodities and their derived products unless they are deforestation-free, legally produced, and covered by a due diligence statement. These three conditions are cumulative: all must be satisfied simultaneously.
The Regulation's Stated Objectives
Article 1 of the EUDR sets out the regulation's purposes clearly. The regulation aims to:
- Minimise the EU's contribution to deforestation and forest degradation worldwide.
- Reduce greenhouse gas emissions caused by deforestation and forest degradation.
- Reduce the EU's contribution to biodiversity loss globally.
- Promote the consumption of commodities and products from legal and sustainable supply chains.
- Support forest protection by partner countries and regions.
These objectives link the EUDR directly to the EU's broader commitments under the European Green Deal, the EU Biodiversity Strategy 2030, the Paris Agreement, the Convention on Biological Diversity, and the UN Sustainable Development Goals. The regulation is not a standalone measure: it is one pillar within a coordinated architecture of EU environmental and climate legislation.
The Three Core Requirements of Article 3
Article 3 is the heart of the regulation. It establishes a flat prohibition with three cumulative conditions. No relevant commodity or product may be placed on the EU market or exported unless all three are met simultaneously:
| Condition | What It Means | Key Implication |
|---|---|---|
| 1. Deforestation-free | Produced on land not subject to deforestation after 31 December 2020 | Requires tracing commodity to its exact production plot |
| 2. Legal production | Produced in compliance with relevant legislation of the country of production | Covers land rights, environmental law, labour law, FPIC, and more |
| 3. Due diligence statement | Covered by a valid statement submitted through the EUDR Information System | Operators must declare compliance before placing products on the market |
Three locks, not one
Think of Article 3 as three independent locks on a single door. A product that is deforestation-free but not legally produced does not pass. A product with a due diligence statement but without verified geolocation proving deforestation-free production does not pass. All three locks must be open simultaneously before a product can enter the EU market. This is deliberate: the regulation is designed to prevent operators from satisfying the letter of one requirement while circumventing the others.
Scope: What Is Covered?
The EUDR covers seven relevant commodities and an extensive list of relevant products derived from those commodities, as specified in Annex I of the regulation. The seven commodities are:
- Cattle
- Cocoa
- Coffee
- Oil palm
- Rubber
- Soya
- Wood
The coverage of products extends far beyond the raw commodities. Leather goods, chocolate, furniture, paper, palm-oil-based cosmetics, rubber tyres, soy-based animal feed, and coffee extracts are all within scope. This means that a company manufacturing car tyres (rubber) or selling printed books (paper, wood) is subject to the same obligations as a commodity importer.
Geographic Scope: Where Does It Apply?
The EUDR applies to any relevant commodity or product that is placed on the EU market, made available in the EU, or exported from the EU. This means it covers:
- Imported products from any country in the world (not just high-risk or tropical-forest countries).
- EU-produced products, such as wood from EU forests or cattle raised in EU Member States.
- Exports from the EU to third countries (a frequently misunderstood aspect of the regulation).
The inclusion of EU domestic production and exports is important. It ensures that the regulation is not a discriminatory trade measure targeting developing countries, but a universal standard applied equally to all operators regardless of origin. A German furniture manufacturer using German timber must comply just as a Brazilian timber exporter must comply.
Practical scope: five companies, five different situations
A: A Brazilian beef exporter shipping to Germany must provide geolocation data for all cattle ranches in its supply chain.
B: A Dutch cocoa trader importing from Ghana must verify that none of the cocoa farms were carved from forest after December 2020.
C: A French paper manufacturer using French wood pulp must still comply, because EU production is within scope.
D: A German car tyre manufacturer using Malaysian rubber must trace the rubber to its source plots.
E: An EU retailer selling Indonesian palm-oil-based margarine must ensure its supplier has a valid due diligence statement before stocking the product.
Relationship to the European Green Deal
The EUDR is formally described as a flagship measure of the European Green Deal. It connects to several other elements of the Green Deal architecture:
- EU Biodiversity Strategy 2030: The EUDR protects biodiverse tropical forests that the EU cannot directly regulate but can influence through its market power.
- Farm to Fork Strategy: Sustainable food systems require sustainable sourcing of agricultural inputs, which the EUDR addresses at the supply chain level.
- EU Forest Strategy 2030: Targets sustainable forest management globally; the EUDR is the key trade policy instrument supporting this goal.
- 2030 Climate Target Plan: Reducing emissions from deforestation is one of the fastest and most cost-effective climate mitigation options.
What the Regulation Does Not Cover
Understanding the regulation's limits is as important as understanding its scope. Several important exclusions apply:
- Recycled materials: Commodities and products that have completed their lifecycle and would otherwise be disposed of as waste are excluded. Requiring due diligence on recycled materials would impose costs without environmental benefit, since the original production has already occurred.
- Other ecosystems: The EUDR covers forests as defined by the FAO. Savannas, peatlands, wetlands, and mangroves are not currently covered, though the Commission is required to review and report on potential scope expansion.
- Commodities not in Annex I: Maize, sugarcane, charcoal, and bioenergy are not currently covered, though they are subject to the scope review process.
- Transit goods: Products in transit through the EU (not placed on the EU market) are not subject to the same obligations, though they remain subject to customs controls.
The EUDR is a commodity-specific, environmental due diligence regulation. The Corporate Sustainability Due Diligence Directive (CSDDD, Directive (EU) 2024/1760) is a broader corporate governance instrument requiring large companies to conduct human rights and environmental due diligence across their entire value chains.
These two instruments are complementary and may overlap for large companies in deforestation-linked supply chains. However, the EUDR applies to all operators placing covered products on the EU market, regardless of company size for operators (though SME traders have lighter obligations). The CSDDD applies only to large companies above certain employee and turnover thresholds. A company subject to both must satisfy both sets of requirements simultaneously.
The EUDR's legality requirement overlaps with CSDDD in the area of human rights: both require attention to indigenous peoples' rights, free prior and informed consent, and labour rights in supply chains. Compliance systems that satisfy one can often generate evidence relevant to the other.
Key Takeaways
- 1The EUDR prohibits placing on the EU market or exporting from the EU any relevant commodity or product unless it is simultaneously deforestation-free, legally produced, and covered by a due diligence statement (Article 3's three cumulative conditions)
- 2The regulation covers seven commodity groups (cattle, cocoa, coffee, oil palm, rubber, soya, wood) and hundreds of derived products listed in Annex I
- 3Geographic scope is universal: EU domestic production, imports from any country, and exports from the EU are all covered, ensuring the regulation is non-discriminatory
- 4The EUDR is a flagship measure of the European Green Deal, linking to the Biodiversity Strategy 2030, Forest Strategy 2030, Farm to Fork Strategy, and the 2030 Climate Target Plan
- 5Recycled materials, non-forest ecosystems, and commodities not listed in Annex I are currently outside scope, though the Commission is required to review potential expansion