Understanding your position in beef, cocoa, coffee, palm oil, rubber, soy and wood supply chains
The EU Regulation on Deforestation-free Products (Regulation (EU) 2023/1115, hereinafter referred to as ‘the Regulation’, ‘this Regulation’, or ‘EUDR’) introduced obligations to operators and traders relating to the placing or making available on the Union market, and exporting from the Union of deforestation-related commodities and associated products. The 1st Edition of this document, published in January 2025, provided an overview of how the obligations applied, depending on the company role (operator/trader), size (non-SME/SME), and position in the supply chain (first placing/downstream) within the EU. A 2nd Edition, with minor edits, was published in July 2025. In December 2025, a number of targeted amendments to the EUDR were adopted (Regulation (EU) 2025/2650, hereinafter referred to as ‘the amending Regulation’). This revised version (3rd Edition) therefore updates the original document, emphasizing how the amendments simplify and streamline obligations for various supply chain actors. A distinction is made between: – ‘Upstream operators’ (so called), who are responsible for exercising due diligence prior to placing relevant products on the Union market for the first time or exporting them, and – ‘Downstream operators and traders’, who do not exercise due diligence.
