Important changes to EUDR & CBAM

30 October 2025

New laws and measures will take effect in 2026, including EUDR (relating to deforestation-free products) and CBAM (to encourage more considerate and sustainable production). These are customs-related issues that many importers will encounter. Are you taking account of the important latest changes recently announced by the European Commission?

EUDR summarised

The EUDR is a new European law designed to combat climate change caused by the disappearance and destruction of forests as a result of European consumption and production. In addition to being prohibited from marketing certain products for this reason, you must also be able to show where your raw materials come from.

The rules apply both to seven raw materials and to products that incorporate them:

– Raw materials: cocoa, coffee, wood, soya, palm oil, rubber, cattle.

– Derived products: chocolate, furniture, paper and cardboard, car tyres, bovine hides and skins, other finished products incorporating any of the aforementioned raw materials.

For more information about this, please refer to our previously published article on the subject.

Almost no postponement of EUDR, but some relaxation

It was recently announced that the previously planned phased introduction of EUDR has only been delayed for a very small group of entrepreneurs. The schedule is as follows:
* Large companies: December 30, 2025 (unchanged)
* SMEs: December 30, 2025 (unchanged)
* Sole traders and small businesses: December 30, 2026 (this was June 30, 2026)

Despite earlier speculation, the effective date of EUDR has therefore not been postponed for almost anyone. However, there will be some relaxations to ensure that traders, sellers, and small producers spend less time on their administration.

Overview of EUDR relaxations as of 2026

Trader, manufacturer, or seller?

Do you sell or trade EUDR products that are already on the European market? If products have already been placed on the European market, your due diligence obligation lapses. However, it is important to remain in contact with your partners so that you can also be sure that the due diligence obligation has been met.

Importer?

You are the party that first places EUDR goods on the European market. The due diligence declaration remains your responsibility. We advise you to request the origin data and geolocations of the EUDR goods from all your suppliers so that you can fulfill your obligation.

Small business?

A more flexible approach will be introduced for small businesses from countries with a low risk of deforestation. All this will be recorded in a one-off, simple declaration. If this information has already been processed in a national database, you do not need to take any further action.

For additional information, please refer to the websites of Evofenedex or the RVO.

Source: Evofenedex webinar 10/28/25

CBAM in brief

The CBAM is a European regulation which forms part of the ‘Green Deal’ and covers the import of goods which are relatively carbon-intensive during production. Dutch Customs and the NEa (Dutch Emissions Authority) have been appointed as regulators by the European Commission. Together they are striving to meet Europe’s climate goals.

Commodities which are deemed to be CBAM goods are:

– Cement, fertiliser, (cast) iron and steel, electricity, aluminium and hydrogen

For more information, you can re-read our previously published article on the subject. Please see the Customs website for a complete list of goods.

Major change to CBAM lower limit from 01/01/26

An important change will also apply here. It was recently announced that the lower limit for importing CBAM goods has been shifted from 0 to 50,000 tonnes per year. This means that many businesses will be exempt from the annual mandatory reporting which applies from 1 January 2026.

There will also be a group where it is uncertain whether or not the volume will exceed 50,000 tonnes on an annual basis. We would advise these parties to register as CBAM declarants as a matter of urgency.

Need advice?

Want to know if EUDR or CBAM applies to your products? If so, please contact your regular contact person.