EUDR FAQ: Everything You Need to Know (May 2025 Update)

The EU Deforestation Regulation (EUDR) significantly changes how companies manage their supply chains to ensure products are deforestation-free.

To provide clearer compliance guidance, the European Commission released an FAQ on EUDR. This document also aligns with the upcoming Corporate Sustainability Due Diligence Directive (CSDDD), emphasizing the importance of understanding these directives to ensure proper adherence to sustainability goals.

In response to implementation challenges and industry feedback, the European Commission issued an updated set of FAQs and guidance in April 2025. These updates provide crucial clarifications on traceability, packaging, due diligence frequency, and legal roles within the supply chain.

In this guide, we will cover:

• An overview of the EUDR and the idea behind the EUDR FAQ.
• A summary of the major changes introduced in the updated FAQ in 2024 and 2025.
• A step-by-step approach to EUDR compliance and how LiveEO’s TradeAware solution can streamline this process.

Whether you’re a business owner, compliance officer, or supply chain manager, the EUDR FAQ is essential reading to navigate the complex regulatory environment of the EUDR and ensure your products remain on the EU market.

EUDR April 2025 FAQ Update: What’s New on Traceability, Packaging, and DDS Requirements

In April 2025, the European Commission published a significantly expanded set of Frequently Asked Questions (FAQs) and guidance to support uniform implementation of the EU Deforestation Regulation (EUDR). These updates clarify a wide range of legal, procedural, and technical questions raised by operators and competent authorities. Below is a summary of the key updates:

1. Traceability Enhancements

• Livestock Feed: Due diligence is required only if the feed is itself a relevant product listed in Annex I at the time of feeding (e.g., soya bean flour). If not listed, no DDS is required.
• Multiple DDS Reference Numbers: Customs declarations can now include multiple DDS references, simplifying logistics and reducing administrative burden.
  

2. Clarifications on Product Scope

• Packaging: Packaging used exclusively to protect or carry another product is exempt from EUDR. Only standalone packaging products are in scope.
• Resold or Reused Packaging: Used packaging such as pallets is not subject to due diligence unless repaired with new materials that fall under Annex I.
• Rental Products: Renting relevant products does not constitute placing them on the market and does not trigger EUDR obligations.
• Correspondence: Items of correspondence are confirmed as out of scope, unless they contain regulated products; similarly, rental arrangements do not constitute placing on the market and therefore do not trigger EUDR obligations.

3. Operator & Trader Obligations

• HS Code and Role Definition: Role determination (operator vs. trader) depends on the HS code group. A company importing unroasted coffee (0901 11) is an operator, while a company roasting it (0901 21) is a trader.
• Upstream vs. Downstream: The first EU entity placing a product on the market is upstream. Subsequent handlers are considered downstream.
• Ascertaining Due Diligence: Downstream non-SME operators and traders are required to reference DDS numbers received from upstream suppliers. They are not legally required to review each upstream DDS but may choose to verify plausibility depending on risk.
• Information System Access: Non-EU operators can only access the EU Information System with an EORI number from an EU Member State or the UK (Northern Ireland).
• SME Exemptions: SME traders and downstream operators are not legally required to submit DDSs. Larger companies cannot impose this requirement on them.
• Authorized Representatives: DDSs can now be submitted by an authorized representative acting on behalf of multiple companies within a group.

4. Updated Due Diligence Procedures

• Low-Risk Countries: Operators sourcing from low-risk countries must still collect information as required under Article 9. They are also required to assess the complexity of their supply chains, the risk of circumvention, and the possibility of mixing with products from unknown or higher-risk origins.
• Reimported Goods: Operators may reuse existing DDSs when reimporting goods that were previously placed on the EU market, minimizing duplication in compliance processes.
• Annual DDS (for Frequent Traders): Operators with regular trade flows can now opt to submit DDSs on an annual basis rather than for each shipment or batch. This option is a compliance simplification measure specifically intended for frequent traders and should not be treated as the default.

5. New Technical Guidelines for the Information System (TRACES)

• Amendment Lock During Checks: DDSs cannot be amended once a competent authority has initiated a compliance check.
• DDS Data Limits: Each DDS can include up to 200 products, 500 scientific names, 1,000 production plots, and reference up to 2,000 DDSs—allowing for over 1 million geolocation points under the 25MB file size limit.
• Net Mass in DDS: All quantities must be expressed in net mass (kg), regardless of traditional trade units. Supplementary units may still be required per HS code.
• Export Simplification: No need to file separate DDSs for multiple destination countries in the same export batch.
• Customs Documentation: DDS reference numbers must appear on customs declarations but not on other shipping documents such as intra-EU transport records.
• Multi-Role Access: One operator account can be used for multiple roles (operator, trader, authorized representative).

6. Use of Forest Maps and Country Benchmarking

• Map Use Flexibility: The EU does not mandate the use of a specific map for assessing deforestation risk. National, regional, or global maps—including the Copernicus program or FAO data—can be used.
• Limitations of the GFC 2020 Map: The Global Forest Cover (GFC) 2020 map is not legally binding and must not be relied upon as the sole basis for determining compliance. It may contain spatial inaccuracies or outdated classifications, particularly at local levels. As such, operators are encouraged to use it as a risk-screening tool rather than definitive proof.
• Risk, Not Non-Compliance: Being located in a designated forest area in the GFC 2020 map does not automatically mean a product is non-compliant, but it does signal elevated risk requiring further due diligence.
• Benchmarking Methodology: Country benchmarking relies on FAO’s Global Forest Resources Assessment and other quantitative data. It helps assess relative deforestation risk but is not final or exclusive.

You can download the official updated FAQ PDF here.

EUDR Overview and Timeline

The EU Deforestation Regulation (EUDR), which came into force on June 29, 2023, is a landmark law designed to curb the EU’s contribution to global deforestation.

It mandates strict due diligence requirements for businesses trading in certain key commodities—such as coffee, cocoa, soy, palm oil, rubber, and timber—ensuring these products are deforestation-free.

Under the EUDR, companies must provide proof that no deforestation occurred on the land used to produce these goods after December 31, 2020. A non-EU operator, defined as either a natural or legal person, who places products on the EU market assigns responsibilities to both itself and the first EU-based operator involved.

The regulation’s core objective remains to prevent products associated with deforestation from entering the EU market or being exported from the EU, reinforcing the global push for sustainable and responsible supply chains.

EUDR Compliance Timeline: New Deadlines for Large and Small Operators

The European Union has agreed to extend the regulation’s application timeline by 12 months.

This postponement is intended to give businesses, third countries, and EU member states more time to fully prepare their due diligence systems.

The new compliance deadlines will be as follows:

• December 30, 2025: for large operators and traders
• June 30, 2026: for micro- and small enterprises

Despite this delay, the EUDR’s fundamental goals remain unchanged. Businesses must continue to fulfill their respective due diligence obligations as outlined in the regulation and should for this reason continue working on their compliance efforts.

Once fully enacted, the regulation will apply to products like cattle, wood, cocoa, soy, palm oil, coffee, and rubber, and it will include some derived products as well.

The Business Impact of the New Timeline

The targeted amendment is seen as a strategic move to ensure that all stakeholders, particularly smaller enterprises and operators outside the EU, can implement comprehensive due diligence measures.

These measures include identifying deforestation risks in supply chains and establishing reporting mechanisms to prove compliance with EU rules.

The additional time will also allow businesses to ensure that their monitoring and reporting systems are robust, avoiding potential disruptions once the regulation is fully enforced. Businesses must be prepared to provide diligence reference numbers obtained from upstream processes upon the request of authorities.

In conclusion, while the postponement offers businesses more time to prepare, the key message from the EU remains clear: only deforestation-free products will be allowed on the market, aligning with the EU’s long-term sustainability goals.

Preparing your supply chains for compliance should remain a priority to avoid risks of penalties or product bans in the future.

Read also: EUDR: Get Supplier Data at Scale with TradeAware

What EU EUDR FAQs Are

The EU Deforestation Regulation (EUDR) FAQs are an official set of guidelines published by the European Commission to assist businesses, operators, and stakeholders in navigating the regulation’s complex requirements.

These FAQs are designed to clarify essential aspects of the EUDR, such as its scope, definitions, due diligence obligations, and traceability rules. They also provide guidance on customs regulations and due diligence requirements for relevant commodities entering the EU market.

Topics covered by the EU EUDR FAQs

The EUDR FAQs cover key topics such as:

• Traceability requirements: These outline how businesses must collect and verify geolocation data for each land plot used in the production of regulated commodities, ensuring products are sourced from deforestation-free land.
• Due diligence processes: The FAQs provide detailed guidance on how businesses should assess and mitigate deforestation risks within their supply chains, including risk evaluation and compliance reporting.
• Legal compliance: Operators must ensure that the legal documentation for commodities complies with both national and international regulations, supporting transparency throughout the supply chain.

EUDR FAQs serve as an evolving resource, regularly updated to incorporate new guidance and address concerns from industry stakeholders.

They are essential for businesses aiming to comply with the EUDR’s requirements and avoid penalties by ensuring their supply chains are deforestation-free. Let’s have a look at them in detail:

The original EU Deforestation Regulation (EUDR) FAQs Overview

The original EU Deforestation Regulation (EUDR) FAQs were introduced alongside the regulation in 2023 to offer comprehensive guidance for businesses, operators, and stakeholders.

The FAQs were designed to clarify the fundamental aspects of the regulation, including traceability, due diligence, and the responsibilities of businesses.

They provided effective and preferred methods and details on how operators must comply with the EUDR to ensure that no products contributing to deforestation enter the EU market.

Key Sections in the Original FAQ:

1. Traceability Requirements:
   • Operators and traders were required to collect geolocation data for each plot of land involved in the production of commodities such as coffee, cocoa, soy, and timber. This traceability was essential to verify that no deforestation had occurred after December 31, 2020.
     
     
2. Due Diligence Obligations:
   • The FAQ emphasized the importance of due diligence systems, outlining that businesses had to assess and mitigate risks in their supply chains. This included providing documentation and conducting regular risk assessments to ensure compliance with the regulation.
     
     
3. Scope of Products:
   • The initial FAQ clarified that the regulation applied to a specific list of commodities, including cattle, palm oil, coffee, and rubber, as well as derived products that might contain these commodities.
     
     
4. Legal Compliance:
   • Operators were reminded that they must ensure their products comply with the laws of the country of origin, including environmental and labor regulations. The FAQ provided guidance on verifying documentation to meet these requirements.

The original FAQ served as a foundational document, outlining the basic requirements for compliance with the EUDR and ensuring businesses understood their responsibilities under the new law. 

They have since been expanded and clarified to address new developments and provide more specific guidance on compliance. For updated guidance, check the section EUDR FAQ April 2025 Update above.

2024 EUDR FAQ Update: Key Compliance Clarifications Before April 2025

The 2024 EUDR FAQ update introduced several important clarifications and changes to help businesses comply with the EU Deforestation Regulation more effectively.

These updates built on the original 2023 guidelines, providing more detailed instructions on traceability, due diligence, and product scope.

Below are some of the key changes outlined in the updated FAQ from 2024:

1. Geolocation and Traceability Requirements:

• The updated FAQs clarify that businesses must now provide precise geolocation coordinates for every plot of land involved in the production of commodities like cocoa, coffee, and palm oil. This is crucial for ensuring traceability and proving that products are deforestation-free.
• For bulk-traded or composite products (e.g., products containing different materials from multiple locations), operators must ensure that all plots of land are clearly identified and not mixed with products from unknown or deforested areas. The 2024 update emphasizes that no mass balance chains of custody are allowed.

2. Clarification on Definitions:

• The FAQ now includes stricter definitions for derived products. For instance, commodities such as rubber and their derived products must also meet the EUDR’s deforestation-free criteria.
• The product scope has been expanded to clarify that all components, even in composite goods, need to comply with the regulation, ensuring full traceability across the supply chain.
• The definition of forest degradation has been further refined in the 2024 updates, emphasizing that degradation occurs only if there is a clear causal link between the harvesting activity and the condition of the forest. Changes occurring due to external factors that happen after sourcing are not considered illegal under the regulation. This update provides further clarity for operators assessing risks in timber supply chains.

3. Risk Mitigation and Due Diligence:

• The new FAQ highlights the increased importance of risk mitigation, urging businesses to engage more directly with their suppliers. Companies are encouraged to help their suppliers meet the EUDR’s stringent compliance requirements through capacity-building efforts and monitoring.
• It also introduces the option to duplicate past due diligence statements (DDS), streamlining the submission process for businesses that regularly deal with the same suppliers and commodities.

4. Support for  Producers & Team Europe Initiative:

• A notable addition in the 2024 update is the provision of additional guidance for non-EU producers, including detailed information on compliance checks. This is part of the EU’s effort to provide better support for global supply chains that export to the EU.

These updates aim to simplify the compliance process while ensuring that the regulation continues to effectively address deforestation. Companies are now better equipped to meet the EUDR’s demands, ensuring their products remain compliant as the EU enforces stricter standards across global supply chains. For the most up-to-date guidance, check the section EUDR FAQ April 2025 Update above.

EUDR Compliance Steps for 2025

Understanding the EUDR FAQ is crucial for grasping the regulation’s scope, but successfully complying with the EU Deforestation Regulation requires taking concrete, strategic actions. From collecting precise geolocation data to submitting due diligence statements, businesses must follow specific steps to ensure their products are fully compliant with the regulation’s deforestation-free standards.

Here are the key compliance steps:

1. Collecting Information: Businesses must gather detailed information about their products, including the exact geolocation of the land used for production. This applies to both imported and exported commodities such as coffee, cocoa, soy, and timber. For operators trading commodities like timber, the date of production refers to the entire harvesting period. For cattle, it refers to the entire lifetime of the animal, from birth to slaughter.
2. Risk Assessment: Companies are required to evaluate the risk that the products they deal with might have contributed to deforestation. This involves checking for deforestation-free status and compliance with local laws.
3. Risk Mitigation: If any risk is identified, companies must take steps to mitigate it. This could include working more closely with suppliers, verifying geolocation data, or ensuring that certification systems are in place. Businesses should be cautious in over-declaring geolocations to avoid circumvention risks.
4. Submit Due Diligence Statements (DDS): Operators must submit a due diligence statement through the designated EU Information System, confirming that all necessary checks have been made and the products are deforestation-free. Companies must also ensure they are compliant with other EU relevant legislation when fulfilling their reporting obligations.

Read also: Leveraging Satellite Technology for Sustainable Supply Chains

Need Help? Discover TradeAware

Navigating the complexities of the EU Deforestation Regulation (EUDR) can be challenging, especially for businesses managing extensive supply chains. 

That's where LiveEO’s TradeAware solution comes in. TradeAware is designed to simplify compliance by providing advanced geospatial analytics, helping companies monitor deforestation risks across their supply chains in real-time.

With the updated FAQ clarifying that there’s no maximum plot size (except for the 25mb upload limit for geolocation files), TradeAware’s ability to handle large datasets and streamline the due diligence process ensures that businesses can manage compliance even in more challenging supply chains.

For companies seeking to stay ahead of the regulatory curve, TradeAware offers an all-in-one solution to ensure seamless, efficient compliance with the EUDR. Let TradeAware handle the complexities of due diligence, so your business can focus on sustainable growth.

Contact us to learn more or try TradeAware for free, by signing up to TradeAware Lite:

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