About
The Regulation represents a crucial step towards regulating the entry and export of goods that contribute to deforestation and forest degradation in the EU market. The Regulation introduces mandatory due diligence assessments for operators and traders involved in the trade of relevant products that contain, have been fed with or have been made using cattle, cocoa, coffee, oil palm, rubber, soy and wood.
These assessments require tracking the commodities back to their specific land plots of origin. Commodities and products that fail to meet the requirements will not be permitted for trade. Furthermore, operators and traders must provide evidence that their products do not originate from recently deforested land or contribute to forest degradation.
To ensure compliance, competent national authorities will conduct inspections and report their enforcement activities to the Commission. The competent authorities are also obligated to respond to substantiated concerns and suspend the trade of commodities and products with significant deforestation risks.
The Regulation establishes a benchmarking system that categorizes both EU countries and third countries based on their deforestation and forest degradation risks, ranging from low to high. The assigned risk category determines the specific obligations for operators and authorities, with high-risk countries requiring enhanced monitoring and low-risk countries benefiting from simplified due diligence procedures.
The Regulation sets a cut-off date for the new rules on 31 December 2020, meaning that only products that have been produced on land that has not been subject to deforestation or forest degradation after 31 December 2020 will be allowed on the EU market or to be exported from the EU.
Penalties for non-compliance are included in the Regulation and will be enforced by member states. These penalties include fines proportional to the company's annual turnover in the EU, with a minimum of 4%. Additionally, non-compliant entities may face temporary bans from participating in public procurement processes and accessing public funding.
To facilitate the implementation of the Regulation, various tools and platforms have been established, including the Multi-stakeholder Platform on Protection and Restoring the World's Forests, the EU observatory on deforestation and forest degradation, and the Team Europe Initiative on Deforestation-free Value Chains.
While the legislation replaces the EU Timber Regulation (EUTR), it maintains the existing system for timber and timber products while expanding its scope to cover other commodities and products associated with deforestation. Timber and timber products produced before 29 June 2023 and placed on the market between 30 December 2024 and 31 December 2027 remain subject to EUTR.
In late 2025, EU institutions advanced a targeted simplification of the Regulation together with an additional one‑year postponement of application, citing IT‑system readiness and administrative‑burden concerns.
Who does it impact?
The Regulation applies to "operators" and "traders" producing, importing and/or exporting products that contain, have been fed with or have been made using "relevant commodities", namely cattle, cocoa, coffee, oil palm, rubber, soya, wood, and some of their derived products, such as leather, chocolate, tires, or furniture.
The Regulation defines two types of traders, and sets different requirements for the two.
"Operators" refers to any individuals or entities engaged in commercial activities who place the relevant products on the EU market for the first time, including import, or exports them from the market to third countries.
According to impact assessments conducted by the Commission, the estimated costs for operators will range from EUR 5,000 to 90,000. These expenses will vary based on the complexity and potential risks within each supply chain.
Operators are required to establish and maintain an updated framework of procedures and measures to ensure compliance with the Regulation for products they place on the market or export. Large operators (non-SME) must in addition publicly report on their due diligence system annually. Companies that already have mechanisms in place to monitor their supply chain and trace the origins of their commodities and products will be better equipped to comply with the new Regulation.
A trader is any person in the supply chain other than the operator who, in the course of a commercial activity, makes relevant products available on the EU market after they are placed there for the first time.
For large traders (non-SME) the obligations are the same as those of operators. Small and medium-sized undertakings are not obliged to carry out due diligence, but must collect and retain certain information for five years:
- Contact details of their suppliers and the reference numbers of their due diligence statements
- Contact details of the companies they supply
Additionally, the Regulation mandates national authorities to establish procedures for conducting controls and inspections on operators and traders involved in the trade of these products.
The late‑2025 simplification package (pending final adoption) would require the due diligence statement to be submitted exclusively by the operator who first places the product on the EU market. Downstream operators and traders would not need to submit separate statements but would retain and transmit the original reference number, and micro and small primary operators would submit a one‑off simplified declaration.
Status: In force
The Regulation entered into force on 29 June 2023.
Companies covered by the Regulations must as a starting point comply with the Regulation from 30 December 2024.
However, 19 December 2024, the European Union granted a 12-month additional phasing-in period. This means that companies subject to the regulations will now be required to comply by 30 December 2025 for large operators and traders, and by 30 June 2026 for micro- and small enterprises.
Implementation in Norway
To date, the Regulation has not been incorporated into the EEA Agreement. However, it has been designated as EEA-relevant, and in July 2025 the Norwegian Government announced its intention to work towards incorporating the Regulation into the EEA framework. The Norwegian Government has also clarified that agricultural products, including beef and soya, as well as exports to countries outside the EEA, will be excluded from implementation, as these fall outside the scope of the EEA Agreement.
Once incorporated into the EEA Agreement, Norway will be required to implement the Regulation into Norwegian law. Implementation is expected to take place through a national regulation or legislative amendment.
Thommessen's comments
The Regulation is an integral part of a comprehensive plan to address deforestation and forest degradation globally. It builds upon previous initiatives outlined in the 2019 Commission Communication on "Stepping up EU Action to Protect and Restore the World's Forests", as well as the European Green Deal, the EU Biodiversity Strategy for 2030, and the Farm to Fork Strategy.
By placing the responsibility on operators and traders to trace the origin of their commodities and products, the EU is further enhancing due diligence obligations within its market. This aligns with other EU regulations, such as the Corporate Sustainability Due Diligence Directive.