Latest EUDR updates: Final EUDR text published, new list of competent authorities, Bamboo facts, and more
A monthly dose of EUDR news to support your compliance journey
Hello, Happy New Year, and welcome to the January edition of our EUDR newsletter!
This month’s packed newsletter includes the final EUDR text published including the delay, a new list of competent authorities, and insights into trading bamboo products. Plus some bonus Dilify news!
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At a Glance
#1 Final EUDR Text Published
#2 Updated list of Competent Authorities
#3 Quick fact of the month - Bamboo out of scope
#Bonus Check whether your HS codes are in scope
#1 Final EUDR Text Published
The final amendment to Regulation (EU) 2023/1115 (EUDR) was published in the Official Journal of the European Union on December 23rd, 2024, formally confirming the one-year postponement of EUDR compliance obligations.
The regulation (EU) 2024/3234 has made several key changes to the implementation timeline:
Large companies (non-SME operators and traders) will now need to comply with EUDR obligations from December 30th, 2025
SMEs have until June 30th, 2026 to comply with the requirements
The EU Commission must publish the list of low and high-risk countries by June 30th, 2025 (6 months before enforcement)
The EU Information System for submitting due diligence statements is now live through Commission Implementing Regulation (EU) 2024/3084
The rationale given for the delay is to "allow third countries, Member States, operators and traders to be fully prepared, including, to allow those operators and traders to establish the necessary due diligence systems covering all relevant commodities and products, so as to be in a position to fully comply with their obligations."
Notably, the amendment also adjusts the timeline for timber products: Regulation (EU) No 995/2010 (EUTR) will continue to apply until December 31st, 2028 for timber products produced before June 29th, 2023 and placed on the market after December 30th, 2025. After this date, all timber products will need to comply with EUDR Article 3 requirements regardless of when they were produced.
With the text now finalised and published, companies have a clear timeline to work towards implementing their due diligence systems and ensuring compliance with EUDR requirements. The earlier publication of country risk classifications (by June 2025) will help operators prepare their risk assessments well in advance of the December 2025 enforcement date.
#2 Updated list of Competent Authorities
The EU Commission has provided an updated list of competent authorities who will be checking shipments, as well as additional clarity on the role and powers of Competent Authorities under EUDR.
One significant aspect is their ability to conduct field audits in third countries, subject to cooperation agreements with local administrative authorities. This power enhances their ability to verify compliance, though importantly, they are not required to consult with producing countries when assessing potential non-compliance of products.
For operators sourcing from both standard and high-risk countries, it's important to note that the due diligence obligations remain the same. However, there is a significant difference in the level of scrutiny applied by Competent Authorities - they will check at least 9% of both operators and the quantity of relevant products from high-risk countries.
The Commission has reminded operators that Competent Authorities have been granted substantial powers to ensure compliance, including the ability to:
Conduct checks without prior warning
Request immediate access to data and documentation
Take immediate interim measures such as product seizure
Carry out enhanced scrutiny where substantiated concerns have been submitted by third parties
#3 Quick fact of the month - Bamboo out of scope
An important clarification has been provided regarding bamboo products and their status under EUDR. Products made solely from bamboo are not within the scope of the regulation, even if they fall under HS codes listed in Annex I.
This is because bamboo is classified as a non-wood forest product according to FAO explanatory notes, and therefore does not fall under the 'wood' commodity category as defined within EUDR.
This means that operators importing or trading purely bamboo-based products do not need to conduct EUDR due diligence or submit due diligence statements for these items.
However, it's important to note that if a product contains both bamboo and other EUDR-regulated commodities (such as wood), then the product would fall within the scope of those regulated components.
#Bonus Check whether your HS codes are in scope
We are excited to announce an addition to our tools suite - the HS Code Checker! These tools help you quickly verify whether your products fall within the scope of EUDR based on their HS (Harmonised System) codes.
The HS Nomenclature is a standardised international system developed by the World Customs Organisation (WCO) that uses six-digit codes to classify traded products. While countries may add additional digits for more detailed classification, our tool focuses on the universal six-digit codes listed in EUDR's Annex I.
Try our HS Code Checker today at dilifyhq.com/tools to instantly verify if your product's HS code falls within the EUDR scope.
This tool joins our growing suite of EUDR compliance tools, including our polygon risk checker, compliance requirements checker, and data completeness verifier. As always, our team is available to help interpret results and provide guidance on your specific situation.