EUDR IMPLEMENTATION UPDATE – September 2025
Dear Valued Customer,
We welcome Regulation (EU) 2023/1115, which requires products on the EU market to be deforestation-free, legally produced, and supported by strong due diligence. At James Cropper, we are proactively aligning our operations with EUDR requirements. Our cross-functional team is implementing the necessary systems and procedures to ensure full compliance. We are also pleased to confirm our partnership with Osapiens, whose technology supports our risk assessment and integration with the EU Traces System for due diligence.
We are currently in the final stage of our implementation project. Our team is working diligently to ensure full compliance, and we appreciate your continued support and patience during this important transition. Please see the 3 categories below summarisng product requirements for EU market entry:
- Products manufactured using harvested pulp before 29 June 2023:
- Exempt from EUDR requirements.
- If imported into the EU after 30 December 2025, Taric code Y132 must be used.
- Products manufactured using harvested pulp between 29 June 2023 and 30 December 2025, and placed on the EU market during this transition period:
- Exempt from EUDR requirements.
- No Taric code required.
- Products manufactured using harvested pulp between 29 June 2023 and 30 December 2025, and placed on the EU market after 30 December 2025:
- Must be fully EUDR compliant.
- Requires geographical location data and Taric code C716.
If your products fall under category 3, please bear with us as we are actively working with our pulp suppliers to obtain the necessary geological location data. We have already begun receiving information from some of our pulp suppliers and expect to provide a comprehensive update within the next few weeks.
In addition, the latest update from the European Commission is that they are proposing a 12-month delay to the implementation date of the EUDR legislation due to unready IT systems for due diligence. The proposed delay is intended to ensure that all stakeholders have the necessary tools and support for effective implementation. We will continue to monitor this and ensure we a fully prepared for any updates or changes.
Should you have any questions or require further clarification, please do not hesitate to contact us.
Kind regards,
James Cropper EUDR Project and Compliance Team