Highlights
 

• Large companies can reuse existing DDS for reimported goods
   
• Companies can submit due diligence statements annually
   
• ANRPC S-G asks firms to join initiatives to empower smallholders
   

The European Commission has made significant progress on its promise to streamline compliance procedures vis-à-vis the EU Deforestation Regulation (EUDR), releasing an updated EUDR Guidance Document and the fourth edition of the EUDR FAQ in April 2025. This measure is in response to long-standing demands from industry and international partners for greater clarity and efficiency and will reduce their administrative costs by nearly 30%.
 

Among notable simplifications is the allowance for large companies to reuse existing Due Diligence Statements (DDS) for reimported goods that were previously placed on the EU market. This change significantly reduces the amount of information that must be resubmitted through the EUDR Information System.

Substantial reduction in due diligence filings expected

Another update allows authorized representatives of company groups to submit DDS on behalf of group members. In addition, companies are now permitted to submit DDS annually instead of for every shipment or batch introduced into the EU market. For large downstream companies, the minimum legal obligation is now limited to collecting and referencing DDS numbers from suppliers during their own submissions.

The Commission said these measures are expected to result in a substantial reduction in the number of due diligence filings and are made in response to industry needs.

The objective is to ensure easy, consistent, and efficient data entry by users. The updated Guidance Document and FAQs were shaped by feedback from EU member states, partner countries, and industry stakeholders, aiming for a harmonized implementation of the law across the bloc.

These changes are further supported by a Delegated Act. It specifically addresses stakeholder requests for guidance on product categories and seeks to minimize administrative burdens for both businesses and authorities.

Administrative costs to come down by around 30%

The Commission is also in the process of finalizing the country benchmarking system, to be formalized via an Implementing Act before June 30, 2025, following consultations with member states.

All of these initiatives are projected to reduce administrative costs by approximately 30%, enabling more cost-effective and straightforward compliance. The Commission said the EUDR has already spurred tangible actions on the ground to combat deforestation, climate change, and biodiversity loss.

In support of global implementation, the EC has intensified its dialogue with third countries, businesses, civil society, and international partners. This includes over 300 stakeholder meetings in 2024 and more than 50 webinars, offering 15,500 training spots through multilingual online materials and simulation tools.

Guidance document not legally binding

The Commission noted that the 45-page guidance document is not legally binding, serving solely to explain certain aspects of the regulation. It is meant to be used alongside the official EUDR text and does not replace or modify its legal provisions.

Looking ahead, the EC pledged to continue responding to stakeholder feedback and to issue further guidance where necessary. It also highlighted expanded support to partner countries through the Team Europe Initiative on deforestation-free value chains, helping global partners shift to legal, sustainable production systems.

Jessika Roswall, EU Commissioner for Environment, Water Resilience and a Competitive Circular Economy, said the European Union is committed to implementing EUDR in a transparent manner. The EU’s aim was to reduce administrative burden for companies while maintaining EUDR goals and it will continue to work closely with stakeholders towards this aim.

Benefit for downstream players hailed

Meanwhile, in his reaction to the latest EUDR developments, ANRPC Secretary-General Toh Heng Guan told Helixtap that the simplification of procedures was directed towards large companies on the issuance and reuse of due diligence statements.

“This certainly benefits downstream players, in which confidence is given to them, especially the established larger companies and their stakeholders in the supply chain,” said Mr Toh.

He, however, said it didn’t address issues of digital literacy and resources that smallholders lacked. Large companies will still need to lead and cooperate with government initiatives to push out capacity-building programs for smallholders, as India is now doing with ISNR.

Toh pointed out that ANRPC was working with other Member Governments and stakeholders to promote capacity-building programs on traceability for smallholders, in preparation for EUDR and sustainability.

Manoj Vembu, co-founder and director, TRST01, which is assisting India to meet EUDR, said the EU, through the FAQ4, has simplified some of the downstream operators' requirements. Earlier, they had to generate unique DDS for each transaction, which has been simplified to result in a 30% reduction in time and cost.

“The annual filing of DDS for the same procurement upstream instead for each shipment and authorizing the operators to file on the importers’ behalf are welcome clarifications,” said Mr Vembu. However, on-ground mapping and establishing traceability remain key challenges.