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EUDR compliance. Short check of the updated version of “Frequently Asked Questions Implementation of the EU Deforestation Regulation”. The subjects. Second part
We would share the main questions & answers on the subjects of obligations arising from the EUDR compliance. What happens if a non-EU based operator places a relevant product or commodity on the EU market? Under which circumstances will non-EU based operators have access to the Information System? If a natural or legal person established outside the EU places relevant products on the EU market, according to Art. 7 EUDR the first person established in the Union who makes such products available on the market is deemed to be an operator within the meaning of the Regulation. This means that in this case, there will be two operators within the…
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EUDR compliance. Short check of the updated version of “Frequently Asked Questions Implementation of the EU Deforestation Regulation”. The subjects
We would share the main questions & answers on the subjects of obligations arising from the EUDR compliance. Which actors does the EUDR cover, and where can I find more information about their obligations? The EUDR covers economic actors along supply chains of relevant products listed in Annex I of the Regulation. There are three distinct categories of actors: Operators (sometimes also referred to as “upstream operators”) are natural or legal persons placing a relevant product on the EU market, or exporting from there, for the first time, excluding downstream operators (see Art. 2(15) EUDR). For example: an importer of cocoa beans or a cattle farmer in the EU who…
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EUDR compliance. An updated version of “Frequently Asked Questions Implementation of the EU Deforestation Regulation” on commodities, values and other compliance topics. Second analysis.
You can find below the questions and answers listed by Frequently Asked Questions Implementation of the EU Deforestation Regulation. Is bamboo in scope of the EUDR? What about other products that do not contain or have been made using relevant commodities, but that are listed in Annex I? Products made solely from bamboo are not in scope of the EUDR. Art. 1(1) EUDR defines that for the EUDR the ‘relevant products’ are only those that contain or are made from relevant commodities, amongst them ‘wood’. The definition in Art. 2(2) EUDR also clarifies that for the purposes of the EUDR the HS codes listed in Annex I are only pertinent…
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EUDR compliance readiness: a short analysis of the updated version of “Frequently Asked Questions Implementation of the EU Deforestation Regulation”. The land data
Frequently Asked Questions Implementation of the EU Deforestation Regulation” provide with the approach about which to manage the land data. What type of checks may EU Member States Competent Authorities carry out in third countries in case a product is deemed potentially non-compliant with the EUDR? Competent Authorities may conduct field audits in third countries pursuant to Art. 18(2)(e) EUDR, provided that such third countries agree, through cooperation with the administrative authorities of those third countries. It should be noted that the Regulation does not require the EU Member States’ Competent Authorities to consult producing countries if a product is assessed ‘potentially non-compliant’ or ‘non- compliant’. Will Competent Authorities use…
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EUDR compliance readiness: a short analysis of the updated version of “Frequently Asked Questions Implementation of the EU Deforestation Regulation”. The land information
The Frequently Asked Questions Implementation of the EU Deforestation Regulation”about the land information provides with these questions/answers: Should polygons be provided by means of circumference? There is neither an obligation nor a possibility to provide the plot of land information by means of circumference. For plots of land of more than four hectares (for the production of the relevant commodities other than cattle), geolocation has to be provided using polygons (not a unique central point with a circumference) with sufficient latitude and longitude points to describe the perimeter of each plot of land. How should the place of production of mixed goods be declared? The operator needs to declare the…
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EUDR compliance readiness: a short analysis of the updated version of “Frequently Asked Questions Implementation of the EU Deforestation Regulation”. The compliance rules
The Frequently Asked Questions Implementation of the EU Deforestation Regulation updated on April 2026 answer the following questions on the traceability and compliance: What if part of a product is non-compliant? If part of a relevant product is non-compliant, the non-compliant part needs to be identified and separated from the rest before the relevant product is placed on the EU market or exported, and that part may be neither placed on the EU market nor exported. If identification and separation cannot be done, for instance because the non-compliant products have been mixed with the rest, then the whole relevant product is non-compliant as it cannot be guaranteed that the conditions…
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EUDR: postponement and changes laid down by the EU regulation 2025/2650
The regulation (EU) 2025/2650 of the European Parliament and of the Council of 19 December 2025 amending Regulation (EU) 2023/1115 (deforestation and forest degradation due diligence) as regards certain obligations of operators and traders, provides, among others, with the following new changes: the corrective measures where competent authorities establish that an operator, downstream operator or trader has not complied with the EUDR regulation or that a relevant product placed or made available on the market or exported is non-compliant, they shall without delay require the operator, downstream operator or trader to take appropriate and proportionate corrective action to bring the non-compliance to an end within a specified and reasonable period of time.…
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CBAM Application User Manual. CBAM Declarant Portal ver 1.2
European Commission published on 27.03.2024 the Application User Manual CBAM Declarant Portal ver 1.2 where there are explanations and directions about how to utilise the CBAM Trader Portal (referred to in this document CBAM Declarant Portal). The Carbon Border Adjustment Mechanism (CBAM) Declarant Portal is the interface offered to CBAM Reporting Declarants to submit and manage the quarterly reports in the CBAM Transitional Registry; this document can be submitted in one of the following ways: (a) the importer who lodges a customs declaration for release for free circulation of goods in its own name and on its own behalf; (b) the person, holding an authorisation to lodge a customs declaration…
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WCO, forest protection and customs compliance
The WCO (world customs organization) announced about International Day of Forests (March 2024) that “ …the International Day of Forests is celebrated globally. In 2024, this significant occasion is commemorated under the theme “Forests and Innovation: New Solutions for a Better World.” This celebration serves as a reminder of the indispensable role forests play in sustaining life on Earth, while emphasizing the urgent need for innovative approaches to tackle challenges such as deforestation and wildlife trafficking…”. Indeed, the same press release added that “…despite significant technological advancements that have revolutionized forest monitoring, enabling countries to track and report on their forests more effectively, the challenge of deforestation persists as a…
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The legal nature of AEO between circular economy, compliance and environment protection
The AEO status represents an accidental and non-mandatory element of the customs obligation. This is given by the authorization which is the unique customs decision able to “defining and qualifying” its owner. Indeed, in this way the economic operator becomes reliable within the context of a participatory cooperation relationship with the customs administration. The AEO authorization is an administrative deed released by the national customs entity/bodies in accordance with the EU regulations. This is valid throughout the EU customs territory and, if a mutual recognition agreement is valid, also with third countries; furthermore, despite being regulated in customs regulatory acts, it is important to highlight that it constitutes an authorization…