EUDR: One-year postponement and FAQ analysis

10.01.2025

Regulation (EU) 2024/3234, published on December 23, 2024, postpones the application of the zero-deforestation regulation by one year while introducing adjustments for certain businesses. In November, the European Commission published an updated FAQ and guidance document to clarify operators' obligations. LCB and ATIBT shared their interpretation of this FAQ to support companies in achieving compliance.

Application of the EUDR postponed to December 30, 2025, for all businesses

Regulation (EU) 2024/3234, published in the Official Journal of the European Union on December 23, 2024, amends Regulation (EU) 2023/1115, also known as the "zero-deforestation regulation." This text postpones the application dates of the obligations for operators and traders by one year.

Objective and context

Regulation (EU) 2023/1115 aims to ensure that certain products (such as wood, cocoa, coffee, soy, and palm oil) placed on the EU market comply with the legislation of the country of origin and meet zero-deforestation standards.

However, the complexity of compliance processes, particularly for companies operating across multiple international supply chains, led to the decision to postpone the application of these obligations.

Key dates

For large companies:
The main provisions of Regulation (EU) 2023/1115 (including due diligence obligations) will apply from December 30, 2025.
For SMEs:
For products already covered by the EUTR (Regulation 995/2010), the new rules will apply from December 30, 2025, the same as for large companies.

Country Risk Classification

A list of countries or regions classified as "low risk" or "high risk" will be published by June 30, 2025.

What This Means for Your Business

Operators and major traders should take advantage of this delay to:

Strengthen their due diligence systems.
Gather necessary data from suppliers.
Adopt digital tools offered by the European Commission, such as the dedicated information system.

For companies already compliant with the EUTR, this transition period ensures regulatory continuity while providing time to adapt their systems to the enhanced requirements of Regulation (EU) 2023/1115.

ATIBT and LCB analysis of the new questions in the Commission's FAQ

In November 2024, the European Commission published a guidance document and a third version of the FAQ on the zero-deforestation regulation, providing practical clarifications for operators and traders. These updates address key issues such as due diligence, the management of bulk and composite products, and the implications for subsidiaries and corporate groups. The document analyzes critical points using concrete examples and clarifies obligations related to traceability, product compliance, and applicable sanctions.

Topics Covered:

Definitions of deforestation and forest, essential for assessing compliance.
Requirements for avoiding forest degradation and their impact on the timber trade.
Responsibilities of operators, SMEs, and subsidiaries under the regulation.
Details on the transition period and compliance declarations.
Sanctions for non-compliance and their implications.

ATIBT offers a detailed overview of the obligations and measures to implement for EUDR compliance, focusing particularly on practical challenges and proposed solutions for companies in the timber trade.

Read the EUDR FAQ by ATIBT and LCB