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On May 22, 2025, the European Commission made it official: the EUDR Benchmarking System is now law. Regulation (EU) 2023/1115, better known as the EU Deforestation-Free Products Regulation, just leveled up. The new regulation isn’t a theory. It’s enforceable. And for companies trading in cattle, cocoa, coffee, palm oil, rubber, soy, or wood — this is your final boarding call.
No more ambiguity. No more delays. The enforcement clock is ticking.
What is the EUDR?
The EU Deforestation-Free Regulation (Regulation EU 2023/1115) aims to ensure that products sold or exported within the EU are:
- Deforestation-free (produced on land not subject to deforestation after December 31, 2020)
- Legally produced in the country of origin
This law applies to both EU and non-EU businesses and sets strict rules for placing or exporting certain high-risk commodities on the EU market.
Commodities Covered
The regulation applies to seven high-risk commodities:
- Cattle
- Cocoa
- Coffee
- Palm oil
- Rubber
- Soy
- Wood
It also includes derived products such as: leather, chocolate, furniture, printed paper, pulp, tires, and packaging materials.
Due Diligence Obligations: Article 8 in Action
If you're placing relevant products on the EU market, you must implement a due diligence system with three core elements:
-
Information Gathering
- Geo-location coordinates for each production plot
- Date and time of harvest
- Proof of legal production in the source country
-
Risk Assessment
- Based on country risk (low, standard, high)
- Includes documentation checks and mapping supply chains
-
Risk Mitigation
- Required if risk is not negligible
- Could involve sourcing changes, supplier audits, or documentation upgrades
All due diligence statements must be submitted via the upcoming EU Information System.
Benchmarking System: Country Risk Classification (May 2025 Update)
As of May 22, 2025, the European Commission adopted the final Benchmarking System under Article 29 of the EUDR. Countries are now classified into three risk tiers:
| Risk Level | Due Diligence Impact | Authority Check Rate | | ----------------- | ------------------------ | ------------------------ | | Low Risk | Simplified due diligence | 1% | | Standard Risk | Full due diligence | 3% | | High Risk | Enhanced due diligence | 9% |
High-Risk Countries (2025):
- Russia
- Belarus
- Myanmar
- North Korea
These countries face the most scrutiny. Sourcing from here means deeper documentation, geo-verification, and audit readiness.
EUDR Compliance Timeline
| Date | Milestone | | ----------------- | --------------------------------------------------------------- | | June 29, 2023 | EUDR enters into force | | Dec 30, 2024 | Large and medium companies must comply | | May 22, 2025 | Benchmarking system officially adopted | | June 30, 2026 | Micro and small enterprises must comply | | Dec 31, 2028 | Transition period ends for timber products placed pre-June 2023 |
Implications for Businesses
Enhanced Geo-Location Data
Operators must collect precise geo-coordinates for all land plots. This is not optional. It’s the foundation for proving deforestation-free status.
Compliance Costs
Expect to invest in:
- Supply chain audits
- Traceability platforms
- Supplier engagement and onboarding
- Legal review of sourcing contracts
Risk of Non-Compliance
Failure to comply could lead to:
- Product seizure at EU borders
- Heavy fines
- Market access bans
- Damaged brand reputation
Strategic Actions for Compliance
-
Establish a Due Diligence Framework
- Centralize geo-data, supplier records, and legality documentation
-
Reevaluate Sourcing Strategy
- Prioritize low-risk countries
- Mitigate high-risk exposures proactively
-
Leverage Technology
- Use tools for supply chain mapping, document validation, and reporting
-
Engage Suppliers
- Train, align, and contractually bind them to EUDR readiness
Final Word: EUDR Is Not a Suggestion. It’s the Standard.
With the benchmarking system now final, and the first enforcement wave hitting by December 2024, this is your last chance to take proactive control of your compliance program.
If you’re not tracking geo-data, auditing your suppliers, and reviewing country risk exposure, your competitors will. And they’ll win on cost, credibility, and compliance.
Need help preparing your due diligence program or digitizing your compliance process?
Let’s talk. Before the Commission comes knocking.
