A.P. Moller – Maersk would like to inform you of the next steps in the European Union Deforestation Regulation (EUDR) and the impact the regulation will have on your supply chain.
As of 30 December 2025, large and medium companies will have to submit their Due Diligence Statements (DDS), while for micro and small enterprises, the regulation is effective from 30 June 2026.
The regulation means that cattle, cocoa, coffee, oil palm, rubber, soy and wood, and products derived from them must be deforestation-free. In preparation for the EUDR, customers importing, exporting or trading intra-EU affected products will have to carry out Due Diligence, by mapping trade flows and collecting information, for example geolocation of plots, supplier and legality details, risk assessing the information and maintaining a repository of collected data.
To be able to place and import products covered by the regulation on the EU market, after completing Due Diligence, operators and traders must submit a Due Diligence Statement in the EU’s Information System . Products that do not fulfil the compliance requirements will will be denied entry into the union, effectively remaining on hold until they are EUDR compliant, resulting in a delay of goods, and additional costs, on top of non-compliance fines.
We strongly encourage customers to make an internal analysis of if and how they are impacted by the EUDR as a first step. Customers need to collect data such as geolocation and the chain of suppliers, as well as do a self-evaluation whether these are compliant with the laws. Our customs consulting team can support in identifying and evaluating the exposure to the EUDR by mapping and analysing data of affected goods and evaluating correctness of HS codes. Likewise, our team can support with preparation and submission of the Due Diligence Statement.
If you wish to discuss the best options for your EUDR compliance, please reach out to your usual contact – our teams remain at your disposal.
Should you have any other questions, or require further assistance, please do not hesitate to reach out to your local Maersk representative.
Frequently Asked Questions (FAQ)
From 30 December 2025, large and medium companies need to prove that affected products are deforestation free. For micro and small companies, the starting date is June 30, 2026.
The seven key commodities under the EUDR are:
- Cattle (including products like beef and leather)
- Cocoa (including chocolate and cocoa-based products)
- Coffee
- Oil palm (including palm oil and derivatives)
- Rubber
- Soy
- Wood (including timber, pulp, paper, wooden furniture, and other wood-based products)
Examples of covered products include:
Raw materials (e.g., logs, soybeans, coffee beans, cocoa beans, crude palm oil, raw rubber)
Processed and semi-processed goods (e.g., wooden furniture, paper, chocolate, leather, tyres)
Deforestation-free means that the product was not produced on land deforested after 31 December 2020. In other words, the land must have been forested or not converted from forest to agriculture after this date.
Forest degradation means damaging a forest, causing it to lose its natural health or diversity. Examples include turning a natural forest into a tree plantation or heavy logging that harms wildlife.
There are several steps you need to follow to ensure compliance with EUDR:
- Map your products and supply chains
List all products and raw materials EUDR covers and trace their origins and suppliers.
- Collect required data
Gather:
- Geolocation data (GPS coordinates) for all production plots
- Proof of no deforestation after 31 Dec 2020 (e.g., satellite images)
- Legal production documents (land rights, permits)
- Product details (type, quantity, country of origin)
- Supplier and customer contact details
- Conduct a risk assessment
Assess the risk of deforestation or illegality in your supply chain. Consider country, supplier, and documentation risks.
- Mitigate risks if needed
If there is more than negligible risk, act (e.g., supplier audits, extra documentation) to reduce it to negligible.
- Submit a Due Diligence Statement (DDS)
Before placing products on the EU market or exporting, you must file your DDS electronically in the EU TRACES system. The DDS must include all collected data and a declaration of compliance.
- Keep records
Store all due diligence information and DDS for at least 5 years, ready for inspection.
You have to submit your Due Diligence Statement through the EUDR information system Trade control and expert system (TRACES).
Yes, authorizing a third party is possible, and it is the most efficient way to ensure compliance. The broker needs to be registered as an authorised representative in EUDR information system Trade control and expert system (TRACES), and you as the company must confirm that the broker can act as your authorised representative.
From 30 December 2025, large and medium companies need to prove that affected products are deforestation free. Micro and small companies need to do the same starting June 30 2026. The obligations do not differ by company size. If a company trades with high-risk countries, a more in-depth Due Diligence is required, than if it trades with low-risk countries.
There are several penalties companies can face as a consequence of non-compliance:
- Fines up to 4% of the company's EU turnover
- Confiscation of the products and connected revenues
- Temporary exclusion from public procurement and public funding
- Serious and repeated infringements can lead to temporary prohibition from dealing in the EU in those products, or for using the simplified due diligence process.
Prior to your first shipment, depending on company size. From 30 December 2025, large and medium companies need to prove that affected products are deforestation free, while micro and small companies need to do the same from June 30 2026.
Our customs consulting team can support in identifying and evaluating the exposure to EUDR by mapping and analysing data of affected goods and checking if HS codes are affected or misclassified. Maersk can also support with preparation and submission of the Due Diligence Statement. For more information, reach out to your local representative.
We are aware of the reports concerning the readiness to implement EUDR at the end of the year, however no official communication has been released by the European Commission on the topic. Our teams continue to prepare for the 30 December 2025 go-live date and urge customers to do the same. Should any announcements on the changes in implementation dates be made by the European Commission, we will inform our customers accordingly.
