Deforestation-free supply chains and due-diligence rules
The EU Deforestation Regulation and similar rules: commodities covered, the 2020 cut-off, geolocation, due diligence and what it means for India.
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About 90% of global deforestation is driven by agricultural expansion, according to FAO. The main drivers are cattle pasture, oil palm, soya, cocoa, coffee, rubber and timber plantations, many of them producing for export. For years, companies made voluntary "zero-deforestation" pledges, but forests kept falling. Governments in major importing markets have now begun turning pledges into law.
The most far-reaching law is the European Union Deforestation Regulation (EUDR, Regulation (EU) 2023/1115). It requires companies selling certain commodities in the EU, or exporting them from it, to prove that the products did not come from land deforested after 31 December 2020, and that they were produced legally. The rules reach far beyond Europe, to millions of farmers in Brazil, Indonesia, West Africa and India.
What the EUDR requires
Covered commodities
The regulation covers cattle, cocoa, coffee, oil palm, rubber, soya and wood, and many products derived from them. These include beef, leather, chocolate, palm oil derivatives, soybean meal, tyres, furniture, paper and printed books.
Three conditions
A covered product may be placed on the EU market only if it is:
- Deforestation-free: produced on land that was not deforested after 31 December 2020. For wood, the forest must also not have been degraded after that date.
- Legal: produced in line with the relevant laws of the country of production, including laws on land use, environment, labour, human rights, tax and the rights of indigenous peoples.
- Covered by a due diligence statement submitted by the operator to an EU information system before the product is placed on the market or exported.
Due diligence
Operators must:
- collect information, including the geolocation of every plot where the commodity was produced (a point for plots under 4 ha, a polygon for larger ones, or for cattle, the establishments where the animals were kept), together with quantities, suppliers and evidence of legality;
- assess the risk of non-compliance;
- mitigate any risk that is more than negligible, through extra information, audits or changing suppliers.
Country benchmarking and checks
The European Commission classifies countries or regions as low, standard or high risk. National authorities must check at least 1%, 3% or 9% of operators handling products from them, respectively. In the first classification (2025), most countries, including India, were rated low risk, with simplified due diligence. That rating does not remove the need to provide geolocation and legality information.
Timeline
The EUDR entered into force in June 2023. Its application to companies has been postponed more than once to give supply chains more time to prepare, with later dates for small and micro enterprises. Exporters should check the current application dates with the European Commission or their buyers.
Geolocating a smallholder coffee plot
A grower in Kodagu, Karnataka, has a 1.5 ha coffee plot. Because it is under 4 ha, a single GPS point (latitude and longitude) is enough. The regulation asks for at least six decimal places, which is about 0.1 m precision; a phone app or field officer can record it. A neighbour with a 6 ha estate needs a polygon tracing the boundary. Satellite images from before and after 31 December 2020 are then checked to confirm that no forest was cleared on either plot. The cooperative keeps EUDR lots separate, or uses records that show which plots supplied each lot.
Other rules and initiatives
- United Kingdom: Schedule 17 of the Environment Act 2021 prohibits large businesses from using forest-risk commodities produced on illegally deforested land. Secondary legislation is required to bring it into force.
- United States: the Lacey Act already bans illegally sourced timber, and forest-risk commodity bills have been proposed in Congress.
- China: has signed joint statements on green and legal supply chains, but has no binding deforestation rule.
- Voluntary systems: certification schemes such as RSPO for palm oil, RTRS for soy, Rainforest Alliance and FSC; company commitments; and jurisdictional approaches, which cover whole districts or states.
Implications for India
India exports several covered commodities to the EU, including coffee, natural rubber and rubber products, leather, wood furniture and paper, and some soybean meal. Indian supply chains often involve many smallholders and aggregators, so the main challenges are:
- Geolocation and traceability for very small plots, often through intermediaries;
- Legality evidence, such as land records and tenure documents;
- Costs of compliance, which can fall hardest on smallholders and small exporters;
- Risk of exclusion, if buyers prefer large estates that are easier to verify.
Commodity boards, such as the Coffee Board and Rubber Board, and exporters have started mapping plantations and building traceability systems, often using mobile apps and satellite checks. India's low deforestation risk rating helps, but compliance still requires data.
Debates
- Supporters argue that binding rules are needed because voluntary pledges failed. They also say traceability brings wider benefits: better market access, premium prices and proof of sustainability.
- Critics argue that the rules are unilateral, add costs for developing countries, and risk excluding smallholders. They also note that "deforestation-free" exports to the EU do not stop deforestation for other markets, a problem called leakage.
- Scope: other ecosystems, such as savannas like Brazil's Cerrado and grasslands, are not fully covered, and their inclusion is under review.
- Support measures: many call for financial and technical support for producer countries and smallholders to make compliance fair.
Key points
- Agriculture drives about 90% of global deforestation.
- The EUDR (Regulation 2023/1115) covers cattle, cocoa, coffee, oil palm, rubber, soya and wood, and their derived products.
- Products must be deforestation-free after 31 December 2020, legal, and covered by a due diligence statement.
- Due diligence requires plot geolocation (a point under 4 ha, a polygon above), risk assessment and mitigation. Checks are 1%, 3% or 9% of operators for low-, standard- or high-risk countries.
- Application dates have been postponed more than once; check the current timetable.
- For India, the key issues are geolocation and traceability for smallholders in coffee, rubber, leather and wood.
What the exams ask
- Explain the objectives and main requirements of the EU Deforestation Regulation.
- List the commodities covered and the cut-off date.
- Describe due diligence and geolocation requirements.
- Discuss the implications for smallholders and Indian exporters.
- Compare mandatory regulation with voluntary certification.
Described in general terms: the kind of examination, not a past paper. Laisha never reproduces exam questions.
Questions people ask
Does the EUDR apply to products sold in India?
No. It applies only to products placed on the EU market or exported from it. Indian exporters supplying EU buyers must provide the required information, but domestic sales are unaffected.
Is a certified product automatically compliant?
No. Certification schemes such as Rainforest Alliance or FSC can help gather information and reduce risk, but the operator remains responsible for due diligence and must still provide geolocation and legality evidence. Certification is a tool, not a substitute.
Why 31 December 2020?
The cut-off date was chosen to match commitments in the Glasgow Leaders' Declaration on Forests and Land Use and earlier company pledges. It also avoids penalising land cleared long ago, while preventing a rush to clear forest before the law took effect.
Sources
- European Union. Regulation (EU) 2023/1115 on the making available on the Union market and the export from the Union of certain commodities and products associated with deforestation and forest degradation. Official Journal of the European Union, 9 June 2023.
- FAO. Global Forest Resources Assessment 2020, and FRA 2020 Remote Sensing Survey. FAO, Rome, 2020–2022.
- Pendrill, F. et al. "Disentangling the numbers behind agriculture-driven tropical deforestation." Science 377, eabm9267 (2022).
- European Commission. Guidance Document for Regulation (EU) 2023/1115 on Deforestation-Free Products. Brussels, 2024.
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