EUDR simplification: what it means for wood and rubber FSC / Jonathan Perugia FSC / Jonathan Perugia May 7, 2025 Category : EUDR The European Commission recently announced a package of measures aimed at simplifying EUDR implementation. The approach behind this package is to pursue simplification through clarification. This includes: A revamped EUDR guidance document A fourth iteration of the FAQs. A draft delegated act – clarifying products that fall into the EUDR scope. While the core requirements remain unchanged, several updates are highly relevant for businesses dealing with wood and natural rubber. Here's what matters most: Clearer scope for rubber and wood products The draft delegated regulation provides a clearer definition of which products fall under the scope of the EUDR. Previously, some rubber and palm oil product codes created confusion because they included both items derived from these commodities and those made from unrelated materials. The new draft addresses this by adding the prefix “ex” (meaning extract) before the HS code in Annex I to indicate that only certain products under that code are covered, specifically, those derived from the relevant commodity. For example, HS code 4011 covers all types of pneumatic tyres, but only those made with natural rubber (not synthetic rubber) are subject to EUDR requirements. Similarly, while rubber from Hevea brasiliensis is included in the scope, other natural gums like balata, gutta-percha, guayule, and chicle from different species are excluded. For the wood sector, it’s confirmed that products made entirely from bamboo or rattan are out of scope. Out of scope: waste, samples, packaging Several exemptions are now additionally proposed: Waste, used, and second-hand wood and rubber products are not subject to EUDR. Product samples of negligible value (like a wooden or rubber item sent for testing or marketing) are excluded. Packaging materials, when used to support or carry another product, are also out of scope. Accessory materials (manuals, labels, catalogs) and letters are excluded, unless they contain relevant products. Products made from rattan or bamboo are not in the scope of the EUDR Geolocation & forest maps: no single map is binding Satellite data, such as the Global Forest Cover 2020 map, can support companies in assessing deforestation risks, but no single map is mandatory, exclusive, or legally binding under the EUDR. Companies can use different maps and tools with the final goal of conducting thorough risk assessment assessments. Ultimately, it remains the responsibility of companies to provide credible and compelling evidence to support their risk assessments. Some level of due diligence needed—even for “low risk” areas Operators sourcing wood or rubber from “low risk” regions benefit from simplified due diligence, but this does not mean only collecting information. The purpose behind EUDR is to reduce deforestation and degradation risk to a negligible level. Companies must still assess the complexity of the supply chain and risks of circumvention. DDS flexibility & annual submissions The due diligence statement (DDS) can now be submitted once per year, covering multiple shipments. Composite products require due diligence only for the main relevant commodity (e.g., rubber soles on shoes). Re-use of existing due diligence statements The EUDR FAQs introduce the concept of ‘downstream operators’ - companies selling or exporting products whose components have already gone through EUDR due diligence. Large companies (i.e., downstream non-SME operators and non-SME traders) can now reuse the due diligence statements submitted by upstream suppliers. Verifying the upstream's due diligence system is not mandatory. Their main tasks are to collect and verify the upstream due diligence reference and verification numbers and submit their own statements referring to them. However, if part of the relevant product has not been covered by due diligence yet, companies must still carry out a full due diligence exercise. For Non-EU Operators Access to the EU Information System requires a valid Economic Operators' Registration and Identification (EORI) number, even for exporters outside the EU. How FSC Can Help Even with these proposed simplifications, EUDR compliance remains a commitment to assess and reduce risks of deforestation—especially for companies sourcing from varied or global supply chains. The FSC system offers a robust foundation and comprehensive tools to streamline EUDR requirements: FSC certification already meets EUDR requirements and is aligned with EUDR-specific definitions FSC Aligned for EUDR provides the voluntary option to ensure EUDR compliance to max extent and helps verify legality and deforestation-free sourcing FSC Risk Assessments help evaluate risks per national and sub-national level, including for composite or low-risk origin products. The FSC Risk Hub provides access to relevant information. FSC Trace supports submitting DDSs and stores information in a reliable way. As companies adapt to the new rules, FSC remains a key partner in building accessible, efficient compliance systems that reduce risk and support market access, balancing competiveness and sustainability needs. Learn more: fsc.org/en/fsc-eudr. FSC’s responses to the introduced changes and simplifications Following our assessment of the changes and simplifications introduced in the EUDR Guidance (version 2) and FAQs (version 4), we do not anticipate any immediate changes to the FSC Regulatory Module. However, we are preparing clarifications in our FAQs to help stakeholders understand the implications of these updates and support their alignment with the new guidance What’s Next? The draft delegated act is open for feedback until 13 May 2025. Afterwards, it needs to be adopted by the EU Parliament and the Council. The EU Commission is also working on the act to benchmark countries, which is set to be issued before June 2025. EUDR requirements are set to become applicable for non-SMEs by Jan 2026. It is time to act and turn compliance into an opportunity. EU Commission Resources: EU Commission press Draft delegated act FAQs (4th iteration) Updated guidance document Contact FSC For further inquiries about FSC's EUDR solutions, please contact eudr@fsc.org.