A quiet shift with enormous consequences is coming to supply chains across Europe - and Irish businesses need to start preparing now.
The EU Deforestation Regulation (EUDR), which was first introduced in June 2023 and comes into force at the end of 2025, marks a fundamental change in how companies must prove the environmental sustainability of their products. It goes well beyond previous legislation and places strict new obligations on importers, producers, and exporters to ensure that certain goods are not linked to deforestation.
And the impact on both Northern Ireland and the Republic of Ireland, will be significant.
A New Era of Environmental Accountability
While regulations like the EU Timber Regulation (EUTR) and the UK Timber Regulation (UKTR) have been around for a while, they’ve done little to halt global forest loss. One major reason? They focused narrowly on illegal logging, without addressing the broader drivers of deforestation.
The EUDR aims to change that. It covers not only wood, but also other key agricultural commodities widely linked to deforestation: soy, palm oil, cattle, coffee, cocoa, and natural rubber, along with products derived from them - everything from leather goods and flat pack furniture, to coffee pods and cardboard boxes.
According to the European Commission, agriculture accounts for 90% of global deforestation, yet much of that activity has been perfectly legal in the countries where it takes place. Between 2013 and 2019, 30% of deforestation tied to commercial agriculture in tropical regions was entirely legal under local laws.
This is where the EUDR draws a firm line: legality in the country of origin is no longer enough. To access the EU market, products must be demonstrably deforestation-free.
Ireland: Fully In, With Nuance in the North
The Republic of Ireland, as a full member of the EU, will implement the regulation in full. Businesses operating here must be able to show that all in-scope products - whether imported, produced locally or exported - meet EUDR requirements.
Northern Ireland is in scope of EUTR, and it is still being discussed in terms of its exposure to EUDR.
What Does Compliance Actually Involve?
If you are a non-SME company based in Ireland and your business handles any of the regulated commodities or products derived from them, you will be classed as an “Operator” or “Trader” under the regulation. You’ll need to conduct (or ascertain) due diligence and risk assessment then submit a Due Diligence Statement (DDS) for each shipment (or batch) - whether it’s coming into, moving within, or leaving the EU.
Downstream SME Operators and Traders do not need to submit a DDS if the goods in question already have a DDS reference number from upstream trade, but they have legal obligations to store records of upstream information and, in the case of an Operator, are obliged to pass pertinent information to downstream customers.
That statement must include detailed information such as:
- The commodity code and product description
- Volume details
- Geolocation data for every point of origin (e.g. the farm or forest where the raw material was sourced)
- Evidence that there is a negligible risk of the product being linked to deforestation
- Names and addresses of upstream suppliers
For land areas over four hectares, geolocation must include a polygon - a mapped outline of the area - not just a single GPS point. This will likely be one of the trickier aspects for businesses to manage, especially those dealing with fragmented or opaque supply chains.
The stakes are high. Penalties for non-compliance include:
- Fines of up to 4% of annual turnover
- Seizure of goods
- Restricted access to EU markets
- Even the possibility of criminal prosecution for company directors
What About Packaging?
Like with the EUTR, if your packaging is made from virgin wood fibre or a mix of virgin and recycled materials, it likely falls within scope of the EUDR.
The regulation covers products listed under several HS code chapters, including:
- Chapter 47 – Wood pulp
- Chapter 48 – Paper and paperboard
- Chapter 49 – Printed materials
For instance, folding cartons under HS code 48192000 are specifically listed. That means packaging manufacturers, printers, and even food producers using those materials will need to carry out due diligence.
There are some exemptions - such as 100% recycled materials, bamboo-based packaging, packaging that is used only as a cover for another product - even if that product itself is in scope (e.g., packaging for beef products or wrapping for paper rolls), and materials used solely to secure loads - but the line between what’s in and what’s out is still quite thin so businesses should review their product classifications carefully - please see Annex 1 of the legal text here.
The Irish Context: Awareness Still Catching Up
So far, Irish media coverage of the EUDR has been relatively low, and many businesses remain unaware of the looming deadline. The regulation will come into effect from 30 December 2025 for large enterprises, with SMEs given a further six months until June 2026. So until then, the requirements of the EUTR will apply.
Despite the delay, data gathering and supplier engagement required will take time. Mapping your supply chains, verifying the origin of raw materials, and collecting the necessary geolocation information is no small task - especially for companies that don’t currently have full visibility.
What Can Businesses Do Now?
Whether you're a food producer, a packaging company, or a logistics provider, the first step is to assess your exposure:
- Do your products include or rely on any of the listed commodities?
- Where do your materials come from, and how much visibility do you have over their origin?
- Will your suppliers be able to provide geolocation data?
From there, businesses should begin building or investing in due diligence systems - like Interu - to help manage traceability, data collection, and risk assessment.
Many companies are already turning to external due diligence providers to help manage the complexity, especially in gathering data from suppliers and preparing for the submission of DDSs to the EU’s central Information System, Traces NT.
Getting Ahead of the Curve
In the coming years, traceability will become a defining feature of market access - not just a sustainability talking point. The EUDR is part of a broader trend of environmental and human rights due diligence legislation that is reshaping what it means to do business responsibly.
For Irish businesses, this is a chance to lead rather than lag. With the right systems in place, companies can not only meet their legal obligations but also strengthen supplier relationships, reassure customers, and align with growing global demand for sustainable products.
Learn more about how Interu can help protect and elevate your business here.
