Although the Regulation entered into force in 2023, the legislator granted SMEs a deferred application deadline, which will expire shortly.
Key points in brief – for SMEs
- The EUDR covers a wide range of raw materials and derived products (e.g. soy, cocoa, coffee, timber, rubber, palm oil).
- From 2026, these products may only be placed on the market or exported from the EU if they originate from deforestation-free areas.
- SMEs will also be subject to detailed documentation and traceability obligations.
- In the event of non-compliance, severe sanctions may be imposed (confiscation of goods, market bans, substantial fines).
- As preparation is time-consuming, it is advisable to start as early as possible.
What is the objective of the EUDR?
The purpose of the EUDR is to significantly reduce the European Union’s contribution to global deforestation and forest degradation, particularly through imported products and goods placed on the EU market.
As a major consumer market, the EU has indirectly played a role in these processes. The new regulation therefore focuses on increasing the transparency and verifiability of supply chains.
Which SMEs are affected?
The EUDR applies to so-called relevant commodities and their derived products, in particular:
- cattle
- cocoa
- coffee
- oil palm
- rubber
- soy
- timber
Applicability is not sector-specific. The Regulation may affect, among others, traders, manufacturers, importers, exporters and processors, even where the relevant raw material is only indirectly present in the product.
What does compliance mean in practice?
From 2026, SMEs will be required, inter alia, to:
- map their supply chains,
- obtain supplier declarations and geolocation data,
- carry out risk assessments,
- submit a due diligence statement in the EU IT system,
- establish internal compliance procedures.
Why is it advisable to act now?
Experience shows that EUDR compliance is not merely an administrative formality, but rather a strategic supply-chain project requiring supplier coordination, contractual amendments and internal process development.
Despite the 2026 deadline, preparation should already begin in 2025, especially for SMEs operating with international supply chains.
Should you wish to assess whether your business is affected and what concrete steps are required to ensure compliance with the EUDR, our firm is at your disposal.
Contact:
Dr. Géza Katona, LL.M.
Attorney at law (Rechtsanwalt)
Katona & Partners Attorneys’ Association
(Katona & Partner Rechtsanwaltssozietät / Attorneys’ Association)
H-106 Budapest, Tündérfürt utca 4.
Tel.: +36 1 225 25 30
Mobile: +36 70 344 0388
Fax: +36 1 700 27 57
g.katona@katonalaw.com
www.katonalaw.com