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Ultimate guide to EUDR

Background and rolling updates on the *DELAYED* European Deforestation Regulation (EUDR) with expert comments and analysis

Image shows EUDR graphic
Image: EU

Update: 15 November 2025

‘A shameful moment and a betrayal’

Why did the EU Parliament vote to delay and amend the European Union Deforestation Regulation weeks before it was supposed to be implemented? Read the full story in the link below for the latest updates.

CocoaRadar view on the EUDR amendment: if the EU can rein in big tech, it can save its own deforestation legislation after ‘a shameful moment and a betrayal’
‘EU deforestation obligations will be postponed one year so that companies can comply with the law that ensures products sold in the EU are not sourced from deforested land’

Update: 11 November 2024

Fairtrade International calls on EU to ignore pressure from EPP as it attempts to derail EUDR

As the European Commission opens due diligence registration for traders, political infighting at the European Parliament threatens to disrupt the European Union's Deforestation Regulation (EUDR) further, cocoaradar.com can report

Fairtrade International calls on EU to ignore pressure from EPP as it attempts to derail EUDR
As the European Commission opens due diligence registration for traders, political infighting at the European Parliament threatens to disrupt the European Union’s Deforestation Regulation (EUDR) further, cocoaradar.com can report

UPDATE: 4 OCTOBER 2024

The European Commission has bowed to pressure and put forward a draft amendment to postpone by 12 months the EUDR rules banning key commodities, like coffee, cocoa, soy, and beef, from entering the bloc if there is evidence they were grown in protected forests.

If approved by the European Parliament and the Council, 30 December 2025 for large companies and 30 June 2026. Since all the implementation tools are technically ready, the extra 12 months can serve as a phasing-in period to ensure proper and effective implementation.

CocoaRadar view: Has the European Commission lost all credibility with its decision to delay the EUDR?
The EC has bowed to pressure and put forward a draft amendment to postpone by 12 months the EUDR rules banning key commodities, like coffee, cocoa, soy, and beef, from entering the bloc if there is evidence they were grown in protected forests.

Meanwhile, cocoa prices continued a downward spiral, with London cocoa posting a one-month low on Wednesday (3 October) after the European Commission unexpectedly postponed its flagship European Union Deforestation Regulation, which was supposed to be implemented on 30 December 2024. 

The law's postponement by 12 months allows certified cocoa stockpiles held at European warehouses to be used to satisfy contracts, reducing concerns that the new law would lead to the cocoa's decertification and limiting existing cocoa supplies.

What happens next?

EUDR postponement: What (legally) happens next?
On Wednesday, 2 October, the European Commission proposed to the European Parliament and European Council a delay in the European Union Deforesation Regulation (EUDR). CocoaRadar asks what happens now concerning the legislative procedure amid pressure from the right

Check out our exclusive Q&A with the European Commission from June 2025, when cocoaradar.com first voiced concerns about the implementation of the EUDR

Exclusive - EC response to 10 questions on the EUDR
While the cocoa sector has broadly welcomed the EUDR legislation, we can report serious misgivings about its implementation, leading to calls for it to be delayed until further guidelines from the European Commission are available.

UPDATE: 27 SEPTEMBER 2024

Image shows a tropical forest under threat from deforestation.
Only commodities and goods sourced from land that has not been deforested since 31 December, 2020 will be allowed into Europe under the EUDR.

With under 100 days to go until the implementation of the European Union Deforestation Regulation (EUDR), CocoaRadar understands that a stakeholders’ platform meeting held behind closed doors in Brussels earlier this week disagreed on a crucial update to technical guidelines and FAQs, leaving cocoa operators, and those of other commodities, who export to the EU, in legal limbo.

More than 28 organisations, including the European Cocoa Association, politicians from EU countries, and international governments, have called for a delay in the regulations (due to come into force on 30 December 2024). However, the European Commission has reiterated its stance against postponing the EUDR, which the EU Parliament passed in June 2023.

German Federal Minister of Food and Agriculture, Cem Özdemir, said in a statement: "The fact that the EU Commission wants to stick to the start of application of the EUDR at the end of the year, even though relevant questions have not yet been clarified, is worrying. This is a problem for German and European companies and businesses. That is why the German government and even the Chancellor have pushed for a postponement - in the hope that the concerns of the member states will be taken seriously.

“The Commission had over a year to create the conditions for a proper and practical implementation of the regulation. This was not successful…”

The regulation affects commodities other than cocoa beans, including cattle, oil cake, soybeans, palm oil, chocolate, coffee, leather hides, paperboard, wood products, and furniture. 

The EUDR decrees that exporters must ensure these commodities and goods are sourced from land that has not been deforested since 31 December, 2020. 

Large companies have an 18-month compliance period, while small firms are given 24 months. Consequently, large firms must comply by December 2024 and small firms by June 2025.

According to sources, European Commission President Ursula von der Leyen is reluctant to delay the implementation of the EUDR because it would necessitate legislative changes and legal unpredictability for operators already struggling with mandatory due diligence statements. 

There are also strenuous calls for Brussels to remain resolute and proceed with the planned implementation.

A ‘pioneering law under attack’ 

Writing in Mongabay, an environment news website, Sam Lawson, described the EUDR as a ‘pioneering law under attack’ 

“There is some understandable frustration that the benchmarking of sources of forest risk commodities as low, standard or high risk has not yet been completed and that there have been delays to European Commission guidance on interpretation of the law.

“However, some of those citing these problems as a reason to delay implementation of the law have a broader agenda to weaken it or even see it overturned. Already, some who initially called only for a delay have begun demanding that low-risk goods be exempt from requirements for traceability.

“Weakening the traceability requirement would be a disaster,” he writes.

According to a report in news channel Euractiv, one scenario is for a ‘soft launch’ with a further transition period and the core requirements of the EUDR remaining in place.

This would mean that while all requirements officially take effect at the end of December, national governments would start with actual enforcement later, in 2025 or 2026.

According to Euractiv, sample verifications and checks would begin later once countries are ready and have prepared their verification systems.

In any event, certification and due diligence experts advise companies to continue, with the expectation of full enforcement in December.

UPDATE: 19 SEPTEMBER 2024

ECA calls for a delay on EUDR, adding more pressure on Brussels as concerns on flagship green policy mount

In a letter sent directly to Ursula von der Leyen, the European Commission president, and seen by CocoaRadar, European Cocoa Association (ECA) president Paul Davis said his organisation ‘respectfully requests that a proposal to delay the date of application of the EU Deforestation Regulation (EUDR) be put forward, in order to provide the additional time that is essential to make this Regulation a success.’

The ECA represents organisations and companies, including cocoa suppliers Barry Callebaut and Cargill and traders Ecom and Sucden. It has called for extending the transition period at least six months from its supposed 30 December 2024 launch.

ECA calls for a delay on EUDR, adding more pressure on Brussels as concerns on flagship green policy mount
We call for the EC to update its guidelines, communicate better with industry stakeholders, and set up regular, joint steering committees as soon as possible if it wishes to retain the little credibility it still has left in implementing the European Union Deforestation Regulation
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COCOARADAR COMMENT
Although the ECA’s letter raised genuine concerns and was drafted from a position as a ‘trusted partner’ of the EC, it is CocoaRadar’s view that the closer to the implementation deadline, the harder it will be for a volte-face from Brussels.
If the EC extends the transition period at this stage, it will necessitate a change in the regulations, adding further confusion, frustration, and anxiety, particularly among smaller operators.
We call for the EC to update its guidelines, communicate better with industry stakeholders, and set up regular, joint steering committees as soon as possible if it wishes to retain the little credibility it still has left in implementing the European Union Deforestation Regulation.

ALERT: Is the EUDR about to be postponed?
Over the past seven days, there has been much chatter about whether the European Commission will propose postponing the EU Deforestation Regulation (EUDR).

The European Deforestation Regulation (EUDR) is a landmark legislative framework aimed at curbing deforestation and forest degradation associated with the European Union’s consumption of commodities. Implemented by the European Commission, the EUDR targets the importation and trade of products linked to deforestation, ensuring that EU market activities do not contribute to the loss of forests globally. This regulation represents a significant step towards sustainable trade practices and the protection of vital forest ecosystems.

Summary of the European Deforestation Regulation (EUDR)

The European Deforestation Regulation (EUDR) was introduced to address the EU’s role in global deforestation through stringent measures on commodities such as cocoa, soy, palm oil, beef, wood and coffee, which are often linked to deforestation.

Key provisions of the EUDR include:

1. Due Diligence Requirements: Companies must perform due diligence to ensure their products do not originate from deforested land post-2020.

2. Supply Chain Transparency: Businesses are required to provide detailed information about the sources of their commodities and ensure traceability throughout their supply chains.

3. Enforcement Mechanisms: The regulation enforces compliance through penalties for violations, incentivizing companies to adhere to sustainable practices.

4. Reporting Obligations: Companies must regularly report their due diligence activities and findings to relevant authorities.

The EUDR seeks to reduce the EU’s deforestation footprint and encourage sustainable land use practices worldwide, contributing to global efforts to combat climate change and biodiversity loss.

Exclusive - EC response to 10 questions on the EUDR
While the cocoa sector has broadly welcomed the EUDR legislation, we can report serious misgivings about its implementation, leading to calls for it to be delayed until further guidelines from the European Commission are available.

Update on the European Deforestation Regulation (EUDR)

As of mid-2024, the implementation of the EUDR is in full swing, with several key developments:

1. Compliance Deadlines: Companies trading in the EU have until the end of 2024 to fully comply with the regulation’s requirements. Non-compliant businesses face significant fines and market restrictions.

2. Technological Integration: Advances in technology, including satellite monitoring and blockchain, are being integrated to enhance traceability and verification of commodity origins.

3. Capacity Building: The EU is providing support to trading partner countries to improve their capacities for sustainable land management and compliance with the EUDR standards.

4. Public Awareness: Increased efforts are being made to educate consumers about the importance of deforestation-free products and encourage more sustainable consumption patterns.

European Commission to open EUDR registry to operators and traders from November 2024
The Deforestation Due Diligence Registry has been published with additional details on the EC’s regulation on deforestation-free products, as major chocolate companies urge the EU not to delay the bill.

These updates underscore the EU’s commitment to enforcing the EUDR and its broader environmental objectives, positioning the regulation as a critical tool in the fight against global deforestation.


28 July 2024: Alarm bells ring over EUDR as chocolate companies urge urgent action from EC on implementation

An influential group of companies and organisations in the cocoa industry has called for the European Commission (EC) to use its full powers enshrined in the European Union Deforestation Regulation (EUDR) to create a special ‘Standing Committee’ to enable “urgently needed coordination and technical discussion” between the EC and operators to “ensure its timely and effective implementation by 30 December 2024.”

Mars, Ferrero, Nestlé, and Tony’s Chocolonely, along with independent watchdog Voice Network and Fairtrade Advocacy Office, signed a joint paper urging the EC to establish a robust coordination mechanism while making clear that the signatories support the new law.

The paper states that one of the first tasks of a proposed EUDR Standing Committee would be to support the provision of guidance and clarifications to member states and companies on how to prepare for EUDR compliance by December 30, 2024, including the use of the Information System.

As seen by CocoaRadar and sent to Brussels last week, the paper states that companies currently need more information and certainty on respecting specific key administrative requirements of the EUDR.

Stress-testing shows limitations of system

Alarm bells are ringing after stress-testing the Deforestation Information System (DIS), used by operators of various commodities to upload their due diligence data, which has ‘shown limitations in terms of content and speed of the Multi-Stakeholder Platform to tackle such operational issues.’

Read the full story in the link

Alarm bells ring over EUDR as chocolate companies urge urgent action from EC on implementation
The cocoa industry has called for the European Commission (EC) to create a special ‘Standing Committee’ to make sure the EUDR can be implemented on time and smoothly at the end of 2024.

Mapping the EUDR: 10 satellite and imagery providers tracing cocoa farms

CocoaRadar scopes out 10 data companies working with cocoa operators to provide accurate polygon maps for EUDR-ready due diligence statements.

Many operators rely on open platforms like Global Forest Watch (GFW), which incorporates open data sets from GLAD, Hansen, and RADD to access near real-time information about where and how forests are changing around the world. However, many experts argue that GFW alone should not be used for EUDR compliance or business-sensitive assessments.

The key lies in how these data sets are utilized and interpreted.

In the article below, we look at 10 satellite and imagery companies that provide data to cocoa operators involved in polygon mapping farms for EUDR compliance.

Mapping the EUDR: 10 satellite and imagery providers tracing cocoa farms
CocoaRadar scopes out 10 data companies working with cocoa operators to provide accurate polygon maps for EUDR-ready due diligence statements.

Rainforest Alliance EUDR certification holders

The Rainforest Alliance certification is one of the standards set for sustainable procurement in the cocoa sector - and other commodities.

As the industry is fully aware, certifications alone cannot prove compliance with the EUDR but can be used to support the data collection process

Therefore, the Rainforest Alliance and other certification bodies have a slight advantage in setting up systems to support producers and supply chain actors in meeting the EUDR's requirements.

In addition, the organisation says its standard requirements already align with the EUDR, and four self-selected requirements have been introduced to cover aspects of the EUDR that were not fully aligned.

“These requirements are only applicable to cocoa and coffee Farm Certificate Holders. Certified farms can choose to implement these additional requirements and have these covered in their audits to support actors further down their supply chains to comply with the EUDR and continue selling their products on the EU market,” it said.

Rainforest Alliance has published its first tranche of certificate holders that have been audited and meet additional EUDR self-selected requirements in the Rainforest Alliance’s Alignment with the EUDR Policy.

Click on the chart below for more details.

16Aug 2024: Fairtrade urges the European Commission to give more farmer support over EUDR

Fairtrade International has urged the  European Commission (EC) to offer more financial support and clarify the technical terms needed for cocoa and coffee producers to meet the 30 December 2024 European Union Deforestation (EUDR) deadline. 

While the organisation reiterates it strongly believes in the EUDR objectives to create sustainable supply chains by preventing the sale and import of forest-damaging products - in a statement to the media, it said it  is “very concerned that producer organisations will be cut off from trade with the EU market or pushed out of supply chains by larger producers not because they farm on deforested land, but because they face challenges in collecting, managing, and submitting the necessary data.”

The 2023 regulation applies to companies placing relevant commodities or products on the EU market or exporting those from it. They must demonstrate that their products are deforestation-free as of the 2020 cut-off date and are not linked to forest degradation or illegal harvesting and trade.

Fairtrade International said this is why it calls on the EC to address the regulation’s shortcomings and help the millions of small-scale farmers at risk. 

It recommends the EC needs to act immediately on:

Fairtrade said it had updated its Cocoa Standard (2022) and Coffee Standard (2024), which require Fairtrade-certified producers to strengthen their deforestation prevention, monitoring, and mitigation. 

“The updated Standards align with the EUDR requirements, including that farms above four hectares in size or in high-risk areas must use polygon mapping, while smaller farms and farms in low-risk areas can use single geolocation points.”

Fairtrade has partnered with tech firm Satelligence to help cooperatives collect data on their members’ farms and deforestation risks. 

The producer organisations provide geolocation data for each of their members’ farm plots. Satelligence’s platform verifies the data, detects any deforestation activity within members’ boundaries, and whether or not farms are located in protected areas. It also flags deforestation near the farm, which is essential information contributing to cooperatives’ risk assessments. Finally, the system generates reports that cooperatives can use themselves and provide to their customers or potential customers.