Since 29 June 2023, EU Regulation (EU) 2023/1115 on deforestation-free products has been in force. Following the latest extension, the obligations will apply from 30 December 2025 (for large/medium-sized enterprises) and 30 June 2026 (for micro and small enterprises).
UPDATE 10.12.2025
The trilogue negotiations on the revision of the EUDR have been concluded: Parliament, Council and the EU Commission have agreed on a postponement of the start of application and on targeted relief for companies along the entire supply chain. The new start date for medium-sized and large companies is 30 December 2026, while micro and small enterprises will be given a deadline of 30 June 2027.
Read more on this topic:
Press release from the European Commission dated 4 December 2025:
➡️ Clarity and predictability to ensure a smooth entry into application of the EU Deforestation Regulation
Press release from the European Parliament dated 4 December 2025:
➡️ Deforestation law: deal with Council to postpone and simplify measures
Press release from the European Council dated 4 December 2025:
➡️ EU deforestation law: Council and Parliament reach a deal on targeted revision
Announcement by the BMLEH dated 5 December 2025:
➡️ Breakthrough in the EUDR (German)
UPDATE 05.12.2025
The trilogue negotiations between Parliament, Council and the EU Commission have been concluded and the institutions have agreed on a further postponement of the EUDR. Large companies will now have until the end of 2026 to implement the requirements, while small and micro-enterprises will have until mid-2027. The background to this includes planned simplifications: in future, only the first distributor will be required to submit a complete due diligence report, while downstream distributors will be relieved of this obligation. The agreed text is to be formally adopted by the Council and Parliament before the end of 2025 and published in the Official Journal of the EU so that the postponement can enter into force in good time.
More on this at: Ad Hoc News | EUDR: EU verschiebt Waldschutz-Gesetz erneut bis Ende 2026 (German)
UPDATE 27.11.2025
After the European Parliament approved a further postponement of the EUDR by one year and a simplification of due diligence obligations, it is now largely following the positions of the European Council. In future, only companies that are placing a product on the EU market for the first time will be required to submit a due diligence statement – reference numbers will no longer need to be collected along the supply chain. Now that all EU institutions have established their positions, trilogue negotiations are set to begin. The postponement of the effective date has not yet been decided; a final decision is expected between 15 and 18 December. If no agreement is reached, the EUDR will continue to enter into force in its current form on 30 December 2025. Read more in the latest newsletter of the BLE:
BLE | Deforestation-free Products Newsletter No. 27 (German)
UPDATE 24.10.2025:
After proposing another postponement of the EUDR on 23 September 2025, the European Commission has now approached the European Parliament and the European Council with a concrete roadmap. In its multi-page proposal, the Commission lists the following key points, which can be found in the BLE newsletter:
BLE | Deforestation-free Products Newsletter No. 25 (German)
Despite the extension, urgent action is required because:
Important: According to the current legal situation, manufacturers from non-EU countries must always submit an extended DDS including geodata if they wish to place products on the market in the EU.
With this regulation, the European Union has introduced new due diligence requirements. These may include the implementation of a comprehensive due diligence system. In most cases, at least a digital due diligence statement must be submitted to the EU information system.
The exact requirements depend on the type of company, its position in the supply chain, its size and the country of origin of the raw material.
Therefore, check in advance what role you play (market participant, trader) and whether you meet the conditions for SMEs. Please note that the role may vary depending on the business process and that, even if you are considered an SME, you may have a different role with extended due diligence obligations due to your position in the supply chain.
For more information, see "Helpful resources" in section 7.
The regulation covers seven raw materials and numerous products made from them:
The products affected are listed in Annex I of the EUDR.
After goods receipt, the reference and verification numbers provided by the supplier can be entered and assigned. This can be done either manually or fully automatically via Papinet messages. Assignment takes place at the roll/batch and delivery note position level – however, for better usability, the data is summarised and displayed at the position level. The numbers can be checked via the C3 TRACES interface at the touch of a button. In goods issue, the products to be delivered are aggregated at delivery note position level and new reference and verification numbers are generated (if necessary) at the touch of a button via the TRACES interface.
Requirement for automatic, consistent number flow between goods receipt and goods issue is active single roll or batch management in C3. If you do not yet use this, please plan an implementation project in good time.
➡️ Note: The EUDR functionality is only available in the latest version of C3.2020. Please check which version you are using and whether you need to upgrade to C3.2020.
There are numerous resources and sources of assistance available for the EU regulation. The Federal Agency for Agriculture and Food (BLE), as the implementing agency, lists many webinars and recordings as well as documents and articles on its website:
✅ Bundesanstalt für Landwirtschaft und Ernährung (BLE)
The BLE offers free initial advice in conjunction with the Business & Human Rights Helpdesk:
✅ Helpdesk on Business and Human Rights
In addition, information on the regulation on deforestation-free products can also be found on the European Commission's website:
✅ EU Commission: Regulation on Deforestation-free Products
Julian Auerbach
Head of Customer Satisfaction Management
Email: j.auerbach@theurer.com
Phone: +49 7141 / 79155‑91
