4 October 2025 · Kemchain team

5 uncomfortable realities of the EU’s anti-deforestation law (EUDR)

A retroactive cut-off date, mandatory geolocation, local legality, the burden of proof and moving deadlines: what the EUDR really asks of companies.

The EUDR can decide whether a product enters the EU market at all. It goes far beyond “saving trees”: it changes how data is managed across the whole supply chain.

More than just saving trees

EU consumption is one of the drivers of global deforestation. Regulation (EU) 2023/1115 aims to break that link by requiring proof, not good intentions.

1. The deadline was yesterday

The cut-off date is 31 December 2020. Any plot deforested after that date is excluded, however well it’s managed today. The law looks backwards.

2. Your product needs GPS coordinates, or it’s out

“No data, no market.” For the seven commodity groups (cattle, cocoa, coffee, oil palm, rubber, soya and wood) you must provide the geolocation of the plots of origin; for plots over four hectares, the full polygon. Mixing untraced origins is no longer an option.

3. It’s not only about forests

Production must also be legal under the laws of the country of origin: land use rights, environmental protection, labour and human rights, Indigenous peoples’ rights, tax and anti-corruption laws, among others.

4. The burden of proof is 100% on companies

Operators must collect information, assess risk and mitigate it before placing products on the market. Certifications such as RSPO or FSC help, but do not remove responsibility.

5. A moving implementation

The goals are clear; the deadlines less so. After two postponements and Regulation (EU) 2025/2650, the EUDR applies to large and medium companies from 30 December 2026 and to micro and small ones from 30 June 2027. The Commission’s simplification review of May 2026 did not change the core text.

Conclusion

Whoever waits for the last date will have to gather in weeks origin data their suppliers don’t have in order. Starting now with structured questionnaires and evidence linked to every raw material is the realistic way to be ready. That’s how we do it with Kemchain Suppliers.

Updated in November 2026 with the current application dates.

Updated: 11 November 2026

Funded by the European Union NextGenerationEU; Government of Spain, Ministry of Industry and Tourism; financed by ENISA; Recovery, Transformation and Resilience Plan; subsidised by CDTI, Government of Spain, Ministry of Science, Innovation and Universities