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EUDR Changes: What Companies Need to Know
The recent changes to EUDR 2025 present new opportunities and challenges for businesses
Published August 25, 2025
Asharita D'Silva
Expert@Era of We
The European Union’s Deforestation Regulation (EUDR) continues to reshape global supply chains by tightening requirements on sustainability, transparency, and due diligence.
While the regulation sets a clear expectation for deforestation-free products, it also introduces significant operational challenges for businesses trading with the EU. Recent adjustments to the EUDR are intended to ease compliance, particularly around administrative burden, without weakening the regulation’s central objectives. From streamlining due diligence submissions to refining benchmarking categories, these changes have meaningful implications for companies navigating EUDR compliance.
Why Do These Changes Matter?
EUDR marks a pivotal shift in trade; no longer can businesses rely solely on cost and efficiency. Instead, sustainability and deforestation-free sourcing have become non-negotiable benchmarks for market access.
However, there are significant challenges associated with EUDR compliance, starting with increased administrative burden. The regulation requires businesses to maintain stringent and comprehensive due diligence systems; this can require some companies to set up new systems and processes to deal with the compliance requirements. In addition, EUDR requires comprehensive data management, and this can add more strain on a business.
The proposed changes to EUDR aim to reduce this administrative burden by simplifying the benchmarking system, reducing the amount of data submission required, and reducing certain obligations.
What Are the Key Changes to EUDR?
- Reuse of Due Diligence Statements (DDSs): Large companies can now reuse existing DDSs when relevant products previously on the EU market are reimported, reducing the level of information required to be processed.
- Authorised Representatives: An authorised representative can submit DDSs on behalf of members of company groups, streamlining the submission process.
- Annual Submission: Companies are permitted to submit DDSs annually instead of in respect of every shipment or batch placed on the EU market, potentially significantly reducing the number of DDSs required.
- Simplified Obligations: Large companies will now be primarily focused on collecting reference numbers of DDSs from suppliers and using those references for their own DDS submissions.
Changes to EUDR Benchmarking
EUDR benchmarking categorises countries based on factors like production trends, current rates of deforestation, and rate of expansion of agricultural land. These criteria are outlined in the legislation and categorise countries as follows:
- Country Risk Ratings (Low, Standard, High)
On 22 May 2025, the European Commission published its country risk classifications under EUDR: 4 countries were labelled high risk, 140 as low risk, and the remainder, including Brazil and Indonesia, are classified as standard.
- How Benchmarking Affects Company Obligations
Low-risk origins: Operators still need traceability, proof of legality, and a DDS, but can skip risk assessment and mitigation steps.
Standard/high risk origins: Full due diligence is required, complete with assessments and mitigation.
- Implications for Market Access and Scrutiny
Products from high-risk countries may face more stringent customs and enforcement scrutiny.
Risk classifications shape investment and sourcing decisions: low-risk sourcing can become a competitive advantage, while standard/high-risk may require supplier capacity support or supplier portfolio diversification.
This benchmarking system is designed to be dynamic in order to incentivise producers to implement more sustainability, traceability, and transparency in their processes. However, this also means sourcing companies need to stay agile and build compliance systems that can be adapted over time.
Furthermore, some have now proposed the addition of a fourth category, “negligible risk”, but this comes with its own set of problems. Most countries, including EU members, are classified as low risk under the current benchmarking system. A negligible risk category would further exempt countries from scrutiny and is supposedly proposed to reflect the reality in some countries with robust sustainability systems.
Concerns Surrounding EUDR Changes
A major concern with the recent changes is that the “low risk” category could potentially open a loophole that would undermine the goals of EUDR.
Operators sourcing from “low-risk” countries can benefit from a “simplified due diligence” obligation and limited checks from competent authorities. The removal of the traceability requirement would make the system vulnerable to fraud and laundering schemes, since products from high-risk countries could be traded as produced in “low-risk” ones, possibly jeopardising the effectiveness of the EUDR, even though the true origin of the product will be reflected in the TRACES system.
The risk categories could also change how and where companies source. For example, a timber company that sources from two origins may choose to only source from the low-risk country to avoid compliance obligations and additional paperwork. This could destabilise existing trade and push small producers away from the global market.
Steps Companies Should Take Now
- Reviewing and Updating Supply Chain Data
Companies should map their sourcing origins down to the plot level, ensuring all suppliers are identified and verified.
This includes updating supplier contracts to reflect EUDR obligations and capturing new data points that may be required for due diligence statements. Regular audits of this data are essential, particularly given the dynamic nature of the benchmarking system.
- Implementing or Enhancing Traceability Tools
Businesses should invest in digital solutions to strengthen visibility across the supply chain. These tools not only simplify reporting but also build resilience if risk classifications change.
- Aligning Due Diligence with Benchmarking Outcomes
For low-risk origins, processes can be streamlined while still maintaining compliance.
For standard or high-risk origins, however, full risk assessment and mitigation remain necessary. Aligning procedures with these risk categories ensures efficiency without sacrificing oversight.
- Training and Internal Policy Adjustments
EUDR compliance cannot be siloed; it requires alignment across procurement, compliance, sustainability, and legal functions.
Companies should update internal policies to reflect the new regulatory landscape, including clear protocols for data collection, risk assessment, and due diligence statement submissions. Training programs are equally critical, ensuring staff understand both the obligations and the rationale behind them.
The EUDR changes provide both relief and new complexities for operators. Key updates include the ability to reuse due diligence statements (DDSs), annual rather than per-shipment submissions, clarified roles for authorised representatives, and simplified obligations for large downstream companies. The revised benchmarking system now classifies 4 countries as high risk, 140 as low risk, and the rest as standard, with potential future debate around adding a “negligible risk” category.
While low-risk sourcing offers streamlined requirements, standard and high-risk origins remain subject to full due diligence, shaping how companies approach supplier engagement, risk management, and investment strategies. At the same time, the proposal for a “negligible risk” category raises concerns over loopholes, enforcement gaps, and potential market distortions.
For companies, the path forward requires proactive adjustments: enhancing traceability systems, reviewing supply chain data, aligning due diligence with shifting benchmarking outcomes, and reinforcing internal training and governance. Success under the evolving EUDR framework will depend on agility and balancing compliance efficiency with the broader imperative of sustainable, deforestation-free sourcing.
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About the author
Asharita D'Silva
Join me in discovering the wonderful world of coffee! As a writer, coffee is my fuel and newfound passion. I love writing about new coffees, sustainability, and coffee culture around the world. I'm always discovering new things about coffee and the industry, which I share with the great community here at Era Of We.
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