This blog post focuses on key aspects of the EU Deforestation Regulation (EUDR) concerning the transition period of the regulation, and what companies should be aware of in this period.
EUDR – A short introduction
The EU Deforestation Regulation (EUDR) is an important milestone in protecting the world’s forests and combating deforestation and forest degradation. The regulation requires businesses to ensure that the raw materials they trade are sourced legally and sustainably. The raw materials the EU aims to ensure are sourced legally and sustainably include coffee, cocoa, soy, palm oil, cattle, plantation wood fiber, and plantation rubber.
The EU adopted the EUDR on December 6, 2022, and it will come into effect at the end of 2025. Deforestation is one of the major causes of climate change and biodiversity loss—two of the most pressing environmental challenges we face today.
EUDR – Transition period
Since the introduction of the EUDR, 4 changes has been made under the category “Other question”. This category has it’s main focus on this period.
The purpose of this post is to provide a bigger understanding of the 4 changes
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9.2 What documentation is required to prove that a product was already on the market before EUDR took effect?
For products placed on the EU market before December 30, 2024, proof is required to demonstrate that they were already in circulation before this date.
The EU accepts the following documents as evidence:
- Customs declarations for imported goods
- Production documents, such as felling permits for wood products or ear tag registrations for cattle
- Delivery notes and invoices that confirm the product was transferred between two legal entities
- CMR waybills for transported goods
If a product can be documented as having been marketed before EUDR took effect, the new regulations will not apply to this product, even if it is sold or processed at a later date.
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9.3 Can products from the transition period be mixed with EUDR-compliant products?
Companies can mix products that were placed on the market during the transition period with products that comply with the new EUDR requirements, provided the following conditions are met:
- Proof of origin: Each batch in a mixture must either have been placed on the market before December 30, 2024, or comply with EUDR requirements.
- Identifiability: Companies must be able to prove that each batch in the mixture is either EUDR-compliant or exempt from the requirements.
- Compliance with traceability requirements: Geolocation data for EUDR-compliant products must remain intact and must not be compromised during the mixing process.
Mixtures where the origin cannot be clearly documented risk being classified as non-compliant with EUDR.
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9.4 How are transitional stocks managed in TRACES?
Companies that store products from before EUDR took effect and continue to sell them after December 30, 2024, must distinguish between products that require a due diligence statement and those that are exempt. This means:
- Only products placed on the market after the transition period must be registered in TRACES.
- Transitional stocks placed on the market before December 30, 2024, do not need to be registered in the system, but companies must be able to provide documentation in case of an inspection.
- When companies mix transitional stocks with new goods, only the new products must be registered in TRACES, while older products must be documented separately.
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9.5 When does the transition period start and end?
- Start date: The transition period began on June 29, 2023, when EUDR officially came into force.
- End date: The transition period ends on December 30, 2024, after which companies must be fully compliant.
- For micro and small enterprises: These companies have a longer deadline and must comply with the requirements from June 30, 2025.
After the transition period, all relevant products placed on the EU market or exported must comply with EUDR unless they can be documented as having been produced and marketed before December 30, 2024.
Stay updated with prduct.com
EUDR is complex, and companies are advised to seek guidance and stay updated to navigate the regulation’s details correctly.
Prduct.com offers a solution that simplifies EUDR compliance. We help you keep track of your HS codes and ensure compliance through automated and reliable data processing. Our platform provides a solution that directly integrates your data into the ‘TRACES’ information system.
In short we collect your data, conduct risk assessments of your entire supply chain, and help mitigate identified risks.
