Postponement of EUDR Implementation Date Approved by EU Parliament

On November 14, 2024, the European Parliament has adopted amendments to the EUDR provisions proposed by the EPP (European People’s Party Group), including the extension of the original date of application of December 30, 2024, to December 30, 2025. Besides this, a new risk category, “no-risk”, was proposed and adopted by the Parliament as part of the benchmarking system. The amendments still need to be approved by the Council, as they go beyond the proposal of the EU Commission. 

As of November 14, all three institutions agreed on the one-year extension of the transition period. 

For context: On October 2, 2024, the European Commission had formally requested a postponement of the application date for the EU Deforestation Regulation (EUDR), a measure designed to regulate the import and trade of products linked to deforestation and forest degradation. The European Council and the European Parliament have now approved this proposal. 

Voting on Amendments Introduced by EPP

On the plenary session, the European Parliament voted for: 

• The postponement of the start of application by 12 months to December 30, 2025 
• A new risk category for the benchmarking system (‘no risk’) 
• Simplifications for companies that source from no-risk countries 

At the very last minute, the EPP had withdrawn proposals on a postponement by 24 months and an exclusion of traders, which is why these were no longer subject to the vote. 

The Way Forward

The result of the voting on November 14, is that the 12-month phase-in, as well as the introduction of a no-risk category, will be resolved via trilogue (meaning, the Parliament, Commission, and Council have to approve this result). This is expected to happen until December 20th, 2024. For the avoidance of doubt, all other aspects and duties of the regulation remain unchanged.  

Support and Clarifications for Practical Implementation

With the postponement, the European Commission has introduced several support resources for affected businesses. These include guidance documents, FAQs, and fact sheets tailored to small and medium-sized enterprises (SMEs), as well as new interpretive guidance clarifying product categories and legal requirements under the EUDR.  

The benchmarking system — a key element of the EUDR — will be published through an implementing regulation by June 30, 2025. This system is intended to provide companies with clear guidance on how to assess supply chain risks. 

Internal Compliance Requirements

It has been confirmed that intercompany transactions involving EUDR-relevant products must also comply with the requirements of the Regulation. This clarification is particularly important for companies working to implement compliance measures at the operational level. 

TRACES Information System

Additional information has been provided on the TRACES information system used for data management under the EUDR. TRACES allows companies to consult up to 2,000 prior due diligence statements (DDS) and clarifies certain limitations of the system. In addition, non-EU companies can access TRACES if they have a valid EORI number. 

Registration for TRACES is available here since November 6th, 2024. Online training sessions will be available starting November 21st, 2024. 

While these new support tools provide additional assistance, they largely reinforce the core assumptions and requirements necessary for successful EUDR implementation.

No Changes for Affected Products

The EUDR will remain applicable to products listed in Annex I of the Regulation if they are produced or harvested after June 29, 2023. Exemptions will continue to apply to products used exclusively for internal purposes, fully recycled materials, or second-hand goods. 

The Directorate-General for Taxation and Customs Union (TAXUD) has also published new TARIC documents containing document codes for import and export transactions under the EUDR. Requirements regarding deforestation, forest degradation, and compliance with legal standards in the producing country have been clarified. Companies are encouraged to consider both product-specific and supply-chain-specific factors in their risk assessments.

Updated Requirements for Mixed Commodities in the EUDR

An update also addresses the classification of products containing multiple EUDR-relevant raw materials. Under the new rule, the primary commodity – identified in the first column of Annex I of the EUDR – determines the classification of the product. For example, in chocolate products, cocoa is the primary ingredient for EUDR compliance, even if palm oil is also used. This update, which differs from previous assumptions, impacts the risk assessment and product categorization process for affected companies. 

osapiens HUB for EUDR: Support for Implementation Preparation

Companies now have the opportunity to establish their compliance activities in a strategic and sustainable way. Those who are already on their implementation journey know that onboarding their supply chain is no small feat and takes time. Instead of relying on point solutions, the EUDR delay allows for the development of long-term systems and processes. Having automated IT systems in place significantly reduces the effort required in day-to-day operations, including automated risk assessments, due diligence statements, and sharing of results across the supply chain. 

The osapiens HUB for EUDR provides an effective solution for implementing the regulation, helping to automate data collection and management processes for greater resource efficiency and sustainability. Over 200 customers already use the osapiens EUDR solution to support a sustainable and efficient future.  

Take Action Now: Prepare for Optimal Readiness

The time leading up to the new deadline is critical to establishing sustainable and efficient processes and advancing EUDR compliance. 

osapiens offers an “EUDR Preparation Checkup” to help companies fully prepare for the upcoming EUDR requirements, even though mandatory compliance does not begin until next year. The osapiens team of experts will help you ensure that all necessary requirements are met and position your company for a smooth implementation. Take advantage of this opportunity to thoroughly understand the EUDR requirements and effectively and proactively adapt your processes.