Inside The European Commission’s Effort to Simplify EUDR Implementation

Last week, the European Commission released three key documents that clarify how EUDR implementation will work in practice. Together, they show where the law is heading and how you can prepare.

1. Press Release
   Aimed at easing concerns, this announcement introduces simplifications designed to reduce paperwork and cut compliance costs—especially for companies handling high volumes or operating across borders. It also links directly to the other two documents:
2. EUDR FAQs – Version 4
   This 80-page document answers common questions from businesses, regulators, and trade groups. It covers everything from geolocation to packaging to animal feed.
3. Updated EUDR Guidance Document
   This guide is more technical, aimed at national authorities who will enforce the law. But it’s useful for companies too. It shows how the EU expects regulators to check whether companies are following the rules.

If you're selling any of the covered products—like beef, soy, palm oil, wood, or coffee—these documents should your new rulebook, even ahead of the EUDR implementation date.

The Core Requirement: Know Your Products’ Origin - Ensure They Are Deforestation Free

At the heart of the EUDR is a simple but strict rule: you must prove your products are deforestation free. And to do that, you need to know exactly where they were produced.

This means gathering GPS coordinates for every farm, forest, or facility that produced the key ingredients in your product. Whether you’re dealing with a soy shipment, a wooden table, or a chocolate bar, you must trace each relevant component back to a specific location.

The EUDR specifically prohibits products and commodities linked with deforestation and forest degradation, including the conversion of primary forests into plantation forests. It also covers derived products, which include various processed items beyond primary commodities.

Here’s how it works:

• For land over 4 hectares: You need to provide a full map outline (called a polygon) of the land.
• For smaller plots or cattle: A single point (latitude and longitude) is enough.
• If you're storing products in silos or tanks, you need to account for everything that went into them—unless you emptied and cleaned them before restocking.

There’s no room for error: if just one part of a batch comes from deforested land, the whole thing is considered non-compliant.

Good News: Some EU Deforestation Regulation Requirements Just Got Easier

The Commission understands that some companies felt overwhelmed by the original rules. So, the new press release outlines a set of simplifications designed to make compliance more manageable—without lowering the bar for deforestation-free goods.

Here’s what’s new:

• You can reuse previous due diligence reports for repeat imports or exports. No need to fill out the same form every time.
• If your supply chain is stable, you can file a due diligence statement just once per year.
• If your company has multiple entities or brands, a single representative can file reports for all of them.
• Large downstream companies (those not doing the initial import) don’t have to redo checks. They just need to confirm their supplier already followed the rules.

For companies with tight margins or limited admin support, these changes can save time and money—without increasing legal risk.

You can read the official announcement for more.

What’s In Scope—and What’s Not?

Understanding whether a product is covered by the EUDR can get tricky, but the updated FAQs make it simpler.

Here’s the gist:

• Only products listed in Annex I of the regulation are in scope. If your product isn't on that list, it's not covered. An ongoing feedback initiative for amendments to Annex I is currently under way.
• Packaging materials are exempt if they’re just used to carry or protect another product. But if packaging (like a wooden pallet) is sold as a product on its own, it’s included.
• Second-hand goods and fully recycled materials are also out of scope—unless they contain new raw material.
• For tyres, only the new rubber components of retreaded tyres are covered, not the reused casing.
• Cattle: All establishments (birth, feed, slaughter) must be geolocated, though only point coordinates are required.
• Feed: Must be deforestation-free if used for livestock whose products are placed on the EU market. No geolocation required unless the feed is placed as a standalone product.
• Second-hand and repaired products: Generally excluded unless repaired with new relevant commodities.

The point is to focus enforcement on materials that cause new land-use change—not waste or reuse.

Satellite Data Will Be Used to Check Your EUDR Compliance Claims

The EU isn’t going to take your word for it. Authorities will use satellite imagery and maps to verify your due diligence statements to ensure your products are indeed deforestation free.

With satellite imagery, it is possible to identify all forest areas that meet the EUDR criteria and monitor changes within these forests.

This is where Earth observation technology comes in. Platforms like Orbify can help you:

• Pinpoint and map each plot of land
• Monitor deforestation in near real time
• Generate concise reports that align with EU requirements
• Stay audit-ready
• Identify potential risks associated with deforestation and land use changes

For supply chain managers, that means less guesswork and more control.

Key Dates and What to Expect Next

Here’s the EUDR implementation timeline:

• 30 June 2025: The EU will publish its country benchmarking system, ranking nations by deforestation risk (low, standard, or high). This will influence the level of due diligence required.
• Full EUDR implementation date: 30 December 2025: This is the date the regulation becomes fully enforceable. After this, non-compliant products can’t be sold or exported in the EU.

Non-compliance with the EUDR can lead to significant penalties and restrictions on market access. If you're hoping for a blanket exemption based on country of origin, think again. Even low-risk countries will require traceability and documentation once the EUDR has been implemented.

Member states are responsible for the enforcement of these regulations, conducting regular monitoring, audits, and checks to ensure compliance. The competent authority within each member state will conduct checks on operators and traders, mandate corrective actions for non-compliance, and implement measures to prevent non-compliant products from entering the market.

Orbify’s Take: EUDR Regulation Can Be Your Competitive Advantage

The updated FAQs and guidance show that the EU is serious—but not unreasonable. They’ve added clarity, made compliance more practical, and created space for technology to help businesses do the job right.

Still, the main message stands: If you can’t prove where your product came from, you can’t sell it in the EU.

Companies that act early will not only avoid last-minute chaos and significant fines—they’ll also be better positioned to meet growing demands for sustainability from customers and investors alike.

Early compliance can help future proof businesses against evolving regulatory landscapes, so why not turn EUDR implementation date into the day your business ran ahead of the curve?

Ready to Prepare Due Diligence Statements?

At Orbify, we help companies use Earth observation to track land use, verify compliance, and simplify reporting.

If you’re navigating EUDR requirements, we’ll help you get there—faster and with more confidence.

Orbify provides the necessary tools to help companies proof their products are truly deforestation free, and to meet their diligence obligations quickly and even ahead of EUDR implementation date!

Ditch the spreadsheets and get ahead with Orbify!

Book a demo or talk to our team today.