Due diligence, traceability, sustainability, and more. What are the challenges and opportunities in the new EU “Zero Deforestation” Regulation?
What is the EUDR Regulation?
The main cause of deforestation in tropical countries is land clearing linked to the expansion of agricultural areas for the production of commodities such as soy, palm oil, beef, cocoa, and coffee. According to the FAO, approximately 203 million hectares of forests were lost worldwide between 1990 and 2025, an area half the size of the European Union.
To counter this trend, the EU has introduced a new regulatory framework aimed at making supply chains more transparent, responsible, and sustainable. Regulation (EU) 2023/1115 on deforestation-free products (EU Deforestation-free Regulation, EUDR) aims to ensure that raw materials like soy, palm oil, beef, cocoa, coffee, rubber, and wood—and many derived products—placed on the EU market or exported from it, do not originate from deforested land and comply with the legislation of the production country.
The EUDR requires operators to implement enhanced due diligence systems based on traceability back to production units and the geolocation of plots to assess and reduce the risk of embedded deforestation along supply chains.
Results and Limitations of the EUTR
To better understand the origins and structure of the EUDR, it is necessary to refer to its precursor: the European Timber Regulation (EUTR). Ten years after its adoption, this regulation achieved some positive results, such as a decrease in illegal timber imports into the EU, increased awareness among market operators regarding illegal logging, and strengthened controls along supply chains.
However, achieving the regulation’s objectives often proved complex and problematic due to an implementation process that was costly in terms of both time and resources.
Implementation Issues of the EUTR
Difficulties encountered in implementing the EUTR have sparked reflection on issues that could also affect the implementation of the EUDR in Member States. Specifically, the lack of human and financial resources allocated to the Commission and competent authorities, initial delays in applying the regulation in some countries, and a limited number of checks accompanied by non-uniform sanctions hindered a shared interpretation and consistent application of the law, especially in the early stages.
Entry into Force of the EUDR and the EU Simplification Process
Despite the initial intent for rapid implementation, the entry into force of the EUDR is experiencing delays. Already postponed by one year to December 2024, it was modified again in 2025 as part of the regulatory simplification process promoted by the European Commission.
As of February 2025, the Commission presented the “Competitiveness Compass,“ an initiative aimed at reducing reporting burdens by 25% and lightening the administrative load for businesses.
Alongside the EUDR, the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD) were also involved in this process through the approval of the “Omnibus I“ package. The CSRD requires companies to report structured environmental impacts and risks, such as biodiversity and land use, while the CSDDD introduces the obligation to identify, prevent, and mitigate negative environmental and social impacts throughout the value chain.
Together, EUDR, CSRD, and CSDDD constitute an integrated regulatory package acting on three complementary levers:
- Product regulation, banning the placement of raw materials linked to recent deforestation on the market.
- Governance and due diligence along value chains.
- Transparency and public reporting to stakeholders.
EUDR Amendments of December 2025
In December 2025, the European Parliament and the EU Council approved several amendments to the EUDR presented by the Commission:
New Deadlines
Businesses will have an extra year to comply with the Regulation:
- From December 30, 2026, for large operators and traders.
- From June 30, 2027, for small operators and micro-enterprises (fewer than 50 employees and annual turnover on affected products below 10 million euros).
The postponement aims to encourage a gradual transition and improve the IT system for submitting due diligence statements.
Simplifications Introduced
Micro and small primary operators will only need to submit a one-time simplified due diligence statement. Furthermore, the due diligence obligation will be limited to companies that first place products on the EU market, excluding downstream operators. Finally, printed products are excluded from the scope of the Regulation.
Overall Changes
The amendment combines a deadline extension with a reduction of certain requirements. While simplification addresses the need to make the Regulation more applicable, continuous delays risk slowing its implementation, creating uncertainty for businesses and leaving forests and ecosystems exposed to persistent negative impacts.
EMMA: From Compliance to Supply Chain Transformation
Companies importing raw materials and products within the scope of the Regulation will be heavily affected and must prepare for adjustment promptly. EMMA is Etifor’s approach that guides companies through a structured path, from risk assessment to building more sustainable supply chains, combining data analysis, operational field support, and strategic consultancy.
The approach is designed to support EUDR compliance and meet CSRD and CSDDD requirements, including the European Sustainability Reporting Standards (ESRS), providing companies with technical expertise and concrete tools