What is EUDR?
Regulation 2023/1115 of 31 May 2023 and its amending regulations (Regulation 2024/3234 of 19 December 2024 and Regulation 2025/2650 of 19 December 2025) are key components of the EU's environmental policy aimed at preventing global deforestation. This act establishes due diligence obligations for entities placing specific goods and products on the European Union market or exporting them from it.
What does EUDR cover?
The goods covered by the EUDR regulation are cattle, wood, cocoa, rubber, coffee, palm oil, and soy. The requirements also apply to relevant products (products made from the aforementioned goods), such as particle board (CN code 44 04). The purpose of the regulation is to ensure that goods subject to EUDR requirements (whether produced in the EU or imported from outside) do not originate from land that has been deforested after 31 December 2020 and that their production complied with the relevant legislation of the country of origin.
EUDR and other regulations
EUDR establishes conditions for the legality of trade – it makes the ability to place a given product on the market conditional upon meeting due diligence requirements. In practice, the regulation supports environmental risk assessment and management. As part of the due diligence system provided for in the EUDR, a mechanism for classifying countries of production according to their level of deforestation risk has been introduced. The intensity of due diligence obligations and the scope of verification activities are tailored to specific risk groups. A three-tier assessment is used, classifying countries as low, standard, or high risk.
When determining a country's risk level, the following factors are taken into account:
- the rate of deforestation and forest degradation in the country;
- the rate of expansion of agricultural land for relevant commodities in the country;
- trends in the production of relevant commodities and products in the country.
Nasze usługi w zakresie oświadczeń EUDR
Wesprzemy Twoją firmę w spełnieniu wymogów rozporządzenia EUDR. Wskażemy, które produkty mogą być objęte wymaganiami oraz sporządzimy kompleksową analizę gotową do przedstawienia odpowiednim organom.
Low-risk countries
Operators and traders sourcing commodities and products from low-risk countries are subject to simplified due diligence. This means there is no requirement to conduct a risk assessment or implement risk mitigation measures. Low-risk countries include, among others, Poland, Ukraine, Germany, Spain, France, Italy, and South Africa. This means that operators sourcing products from Poland (not importing them into Poland!) are subject to simplified obligations.
Trade with standard and high-risk countries
When conducting business with standard and high-risk countries, it is necessary to comply with a due diligence system, where every step taken must be documented. Standard-risk countries include: Venezuela, Peru, Paraguay, Pakistan, Indonesia, high-risk countries include: Russia, Myanmar (Burma), North Korea, and Belarus.
Mandatory requirements include, among others: collecting information regarding the geolocation of production plots, gathering evidence of compliance with national law and other information from suppliers. Additionally, in the case of an operator, i.e., a company that places goods from outside the EU on the Union market, for example from Peru (a country with standard risk), the operator will be required to conduct an individual risk assessment by collecting information from that country regarding:
- the level of corruption there,
- the effectiveness of law enforcement,
- the complexity of the supply chain,
- the presence of land-use conflicts,
- the reliability of the provided documents.
In the event that a risk of non-compliance the operator is required to implement risk mitigation measures, which include:
- independent third-party supplier verification,
- analysis of satellite imagery during specific cultivation periods,
- additional on-site production audits,
- certifications and documentation from other parts of the supply chain,
- random supplier inspections.
Only once the operator demonstrates that the risk has been mitigated to a negligible level will they be able to proceed with submitting a due diligence statement via the IT system. Compliance with this requirement is subsequently verified as part of the oversight system managed by the competent public administration authorities.
Authorities responsible for fulfilling obligations
In Poland, the Ministry of Climate and Environment serves as the coordinating body, under which three authorities have been established.
- The Veterinary Inspection – regarding cattle and relevant products thereof.
- The Agricultural and Food Quality Inspection – regarding cocoa, coffee, oil palm, soy, and relevant products thereof.
- The Environmental Protection Inspection – regarding wood, rubber, and relevant products thereof.
The specific competencies of these authorities include, among others:
- auditing the due diligence system for individual products,
- verification of declarations submitted in the TRACES system,
- document checks and on-site inspections,
- imposition of financial and administrative sanctions.
Sanctions
The regulation provides for restrictions and sanctions in the event that products causing deforestation are placed on or made available in the European market, were not produced in accordance with the laws of the country of production, or if a due diligence statement has not been submitted for them.
The most severe penalties include financial and administrative penalties, which consist of:
- fines of up to 4% of the entity's total annual turnover,
- confiscation of products that do not comply with the requirements of the EUDR regulation
- public disclosure of information in a list of final judgments regarding violations and imposed penalties.
Penalties may also temporarily prohibit the placing of products on the market or exclude a company from public procurement procedures and other forms of public funding. Authorities may also impose an obligation to implement corrective measures and interim measures, such as rectifying formal non-compliance, eliminating any irregularities in the due diligence system, or donating non-compliant goods to charity or for public use.
To summarize this section: It is crucial to precisely define your role in the supply chain, have a thorough understanding of your obligations, and meet the established requirements. This will ensure supply continuity and business liquidity, while also protecting the company from severe financial penalties.
