An Overview of the Updated EUDR Guidance: Implications for Wood Exports

On April 14, 2025, the European Commission released updated guidance and a revised FAQ on the EU Deforestation Regulation (EUDR), aiming to refine the implementation of Regulation (EU) 2023/1115. While the guidance introduces some procedural flexibilities, it also reinforces stringent due diligence requirements that present notable challenges—particularly for exporters of wood pellets. 

Key Changes in the Updated Guidance

1. Annual Due Diligence Statements (DDS) Now Allowed

According to Section 5.19 of the FAQ, a DDS can now apply to multiple shipments over a one-year timeframe. Rather than requiring a new DDS for every shipment or batch, companies can now submit an annual statement provided all shipments covered share identical sourcing and geolocation characteristics. 

This change is meant to reduce the administrative burden for companies dealing with homogenous, stable supply chains. For example, agricultural operators sourcing multiple batches from a single, verified harvest site may find this beneficial.

2. Enhanced Clarification on 'Negligible Risk' and Supply Chain Complexity

The guidance offers improved definitions for assessing negligible risk and elaborates on the role of complex supply chains in risk assessments. It outlines how supply chain fragmentation, varied sourcing locations, and mixed-origin products can elevate the risk of non-compliance. This is particularly relevant for processed wood products like pellets, which often contain inputs from numerous forest sites.

3. Updates on Operator Definitions and Responsibilities

Expanded guidance on the definition of "operator" and clearer distinctions between SME and non-SME obligations aim to clarify accountability within the supply chain. Additionally, traders not classified as SMEs now carry DDS obligations, emphasizing traceability responsibilities throughout the product lifecycle.

4. Clarification on Composite Products and Packaging

For composite products (e.g., furniture, paper products), operators must ensure due diligence on each relevant input listed in Annex I of the EUDR. However, packaging materials used solely to support or protect a product are not covered unless they are marketed independently. 

Industry Concerns: Limited Applicability for Forest Products Exporters 

While the updated EUDR guidance introduces flexibility by allowing annual Due Diligence Statements (DDS), this adjustment may have limited utility for the forestry sector. The structure of forest product supply chains—often involving biomass sourced from a wide range of geolocations—makes it difficult to benefit from this change in practice. Each shipment typically includes material from different harvest plots, each of which must be individually documented with precise geolocation data. This complexity effectively negates the administrative efficiencies intended by the annual DDS option. 

The revised guidance appears more advantageous for agricultural operators that draw repeatedly from the same harvest sites, where batch uniformity simplifies traceability and compliance. However, for wood product exporters whose operations rely on decentralized, small-scale forest inputs, the requirement to document each distinct origin site remains unchanged. This results in a continued need for shipment-specific due diligence. 

Moreover, there appears to be a disconnect between the policy rationale and the logistical realities faced by forest products producers. While some sectors, such as pulp and paper, have welcomed the changes, these endorsements may stem from a partial understanding of how varied and dynamic biomass supply chains operate in practice. In this context, the updated guidance—though helpful in theory—does little to ease the compliance burden for those dealing with highly fragmented sourcing systems. 

Conclusion: More Clarity, But Still Complexity 

The updated EUDR guidance adds helpful detail in certain areas—clarifying roles, timelines, and due diligence parameters. However, for the wood products sector, the new annual DDS allowance may offer little relief, as the granular traceability required by the regulation still necessitates shipment-specific documentation. 

Operators in the biomass and forest-product sectors must continue to invest in robust geolocation tracking systems, supplier traceability tools, and compliance protocols to meet these evolving standards. While the guidance moves the conversation forward, its practical application remains limited for fragmented, multi-source supply chains like those seen in wood exports. 

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