EUDR 2025: preparing your business for EU anti-deforestation rules

The media and industry circles are actively debating a possible postponement of the European Union Deforestation Regulation (EUDR) implementation deadline. Formally, however, the Commission’s October proposal for amendments does not provide any deferral for medium- and large companies. Around 120,000 Polish firms will have to comply with the new requirements. Therefore, it is worth reviewing the key obligations and the latest simplification proposals just before the mandatory entry into application of the regulation.

What is EUDR and to whom does it apply?
The EUDR is an EU regulation aimed at combating global deforestation through the strict control of supply chains for products associated with deforestation risk. It imposes new obligations on producers, importers, processors, and entities in the retail sector – essentially anyone placing on the market products made from wood, cocoa, soy, palm oil, coffee or beef.

The regulation is set to take effect for medium and large businesses on 30 December 2025. Micro- and small producers and importers will receive a six-month extension, and there are ongoing discussions about possibly delaying both deadlines by another year.

However, we observe that larger companies often exert regulatory pressure on smaller partners in the supply chain. In practice, this means that micro- and small businesses adapt to the requirements earlier, aligned with their suppliers’ or customers’ timelines, to avoid losing key business relationships.

Practical obligations: what needs to be done?
The first step is to identify precisely the range of products subject to the regulation and analyse the entire supply chain. It is crucial to determine the company’s operational role – whether it is a producer, importer, or retailer under the Regulation – as this defines the scope of obligations. A review of inventory for EUDR-covered products is also necessary.

The second pillar is implementing a due-diligence system, meaning procedural measures and instructions for monitoring, control and reporting in line with the Regulation’s requirements. Businesses must develop anti-deforestation procedures and incorporate them into supplier agreements.

Compliance with EUDR largely depends on suppliers’ adherence to procedures, as supply chain traceability relies on transmitting unique declaration numbers uploaded into the due diligence system. Without clear cooperation rules, full compliance cannot be guaranteed.

Polish legislation – status and assumptions
At the end of October, the draft national law implementing EUDR was ready for public consultation. The provisions aim to designate supervisory authorities, define document submission procedures, and establish rules for inspections and penalties for non-compliance. The draft also provides for harmonising control procedures with the EU Customs Code.

The project was included in the government’s legislative agenda in fourth quarter of 2025 but was not ultimately submitted for consultation, due to the European Commission’s new amendment proposal to the EUDR Regulation issued on 21 October.

As with all EU Regulations, the EURD imposes obligations directly in member states, including Poland, meaning no changes to national law are required for its application.

Simplification proposals – support for businesses at the finish line
At the end of October, the European Commission proposed measures to improve the operability of the IT system, which would ultimately facilitate EUDR implementation within organisations. The changes mainly concern simplifying reporting – especially for micro- and small entities from low-risk countries, which will be allowed to submit simpler, one-time declarations. For large entities, reporting responsibility will be concentrated on importers introducing products to the EU market, while companies further down the chain within the EU will no longer need to maintain ongoing reporting.

However, they will still be required to collect due diligence declaration numbers uploaded by entities at earlier stages of the supply chain. Therefore, procedural aspects of necessary implementations remain critical.

What’s next for EUDR?
Commission’s proposals undergone the trilogue negotiations stage on 4 December.

Council’s presidency and the European Parliament’s representatives reached a provisional political agreement on a revision of the EUDR, opting for an extension of the application date for all operators until 30 December 2026, with an extra six-month cushion for micro- and small operators, as well as for the obligation to submit the required due diligence statement falling exclusively on the operators who first place the product on the market (so-called ‘first downstream operators’).

The agreement is now to be formally adopted by both institutes. Only if published in the Official Journal of the EU before the end of December, it will replace the text and deadlines of the current EUDR.

Supporting businesses in EUDR implementation for over a year, we see that preparation is time-consuming. Even if the Regulation were postponed for another year, it is wise to treat this time as an opportunity for thorough preparation – especially considering the severity of sanctions.

Sanctions for non-compliance – what to expect?
Companies failing to comply with EUDR will face financial penalties of at least 4% of the annual EU turnover. They may also be subject to confiscation of products and transaction revenues, temporary exclusion from public procurement or access to funding, and even bans on placing products on the EU market or exporting them. Additionally, the list of penalised entities will be published by the European Commissio