World Resources Institute: What the EUDR means for food ingredients supply chains
16 Jan 2026 | World Resources Institute
Tina Schneider, director for Forest Governance and Policy at the World Resources Institute, unpacks what has changed in the recently delayed EU Deforestation Regulation (EUDR), where it could have real power to curb deforestation, and where risks could remain. She also shares where food ingredients supply chains might struggle with compliance — and how we should measure the regulation’s success five years from now.
Hello everyone, my name is Josh Chapaul and I am the senior editor at Food and Greens First, and I'm pleased today to be joined by Tina Schneider, who is Director for forest governance and Policy with the World Resources Institute.
And we're here to discuss the EU deforestation regulation after the EU Parliament agreed to delay its implementation at the end of last year.
So welcome to you Tina.
Thank you.
Could you start by telling us from your perspective, what fundamentally changed in this latest version of the EUDR compared with what was originally proposed?
Sure.
The main differences are that there was, of course, a one-year delay for all actors affected by the EUDR to the date of entry into application, so a pushback from December 30th of 2025 to 30th of 2026.
In addition, the EU institutions agreed to exclude printed matter, so books and newspapers from the scope of the regulation, so those actors no longer have to comply at all.
And there was a change in the requirements for certain actors, so both the actors that are downstream from those that put the, the product on the EU market for the first time.
The first placers, those downstream operators and traders no longer have to submit declarations to comply with the regulation, and also the small and microenterprises that are selling directly to their own market in the EU are also now going to be exempted.
Declarations except for a one-off declaration that they submit initially.
These small and microenterprises also received additional time to prepare, so their entry into application will only happen on June 30th of 2027.
The final thing that's important to mention is that the parliament and council tasked the commission of the European Union with, the conduction, conducting a simplification review.
To make additional changes and suggestions for how to reduce the burden on those that have to comply with the regulation.
Yes, thank you, so that brings us up to speed with the air regulation in its latest form.
Can you tell us what are the strongest elements of the EUDR that could genuinely reduce global deforestation?
In our experience at WRI, what we've seen in looking at similar regulations and laws for the timber sector is that what seems to make a huge difference is having a declaration requirement because it does make a difference if someone has to sign, yes, I have done due diligence and I have determined that there is no or negligible risk, or if they don't have to do that and have a generalized obligation to conduct due diligence, but there is no real process to ensure that they're paying attention to that.
So, in our experience, the declaration requirement is a pretty substantial, you know, centerpiece of the regulation.
And we're really happy to see that that's been retained for most of the actors.
The other thing that's important is the obligation to map and understand your supply chains as someone that is placing product on the EU market or exporting from the EU market, because that's really the thing that will have the most impact in the long run is to really drive this this transformation of supply chains to a sector that in many cases still is struggling.
To figure out where products are coming from and, and who's touching them on their supply chain journey.
OK, and what would you say are the most serious weaknesses or perhaps risks in the current EUDR design?
We think at WRI that it's unfortunate that there was no provision for a test period or some kind of, you know, phased rollout, which would have been much easier to negotiate in this current period because one of the concerns is that the implementation goes from 0 to 100, right?
There's no, there's no period where companies are able to figure out, OK, Is this working for us?
Do we have the systems in place that function appropriately with the IT system that the EU is providing, to work with competent authorities in a way, in the enforcement of, of the regulation to see, to receive feedback and, and sort of, you know, guidance on, on how certain, parts of the regulation might be interpreted by the enforcement authorities, etc.
Etc.
And so, it would have been great to include that.
Unfortunately, that was not done.
And it appears that retroactively, it's hard to include that kind of legal provision.
So, the commission tried to include a grace period of 6 months with limited or no enforcement in their proposal for the delay and revision.
Unfortunately, that was not taken up by the parliament and the council, which we think would have been a much more elegant way of handling this because now you have the same problem as last year in that there is no enforcement, and then on December 30th, 2026, there will be enforcement and there's no, No ability to really sort of work towards a phased approach there.
I do think that some of the competent authorities have tried to provide those services within the framework of their national law, but it's not something that every competent authority across the member states has done.
So, if, if, if there's interest in this, I highly recommend looking at the experience of the Dutch competent Authority, which conducted voluntary pilot audits of companies that fall under the scope of the UDR and they provided some very helpful, I think, guidance on their website on what they found companies were doing right.
Anonymous, of course, and what they found companies were not doing or not doing enough of or where they were falling short of what the Dutch competent authorities decided is the right level of effort for this, for this regulation.
Hm, OK, and in terms of companies, what are you hearing, as the biggest barriers to this compliance?
Particularly with the, the food ingredients companies and, and supply chains?
Yes, a lot of different, issues are coming up across different sectors depending on where you are in the supply chain.
So, of course, if you are a large global actor in the food, you know, trade business, it is difficult because there are so many different products that you have to deal with.
So, it could include paper and, and, and packaging and, and sort of materials that you use.
It included , obviously coffee and, and other, other commodities that you're, that you might be trading, and those commodities are produced in such different ways.
So you have soy, which is often grown in large monocultural plantations, you have coffee, which often is grown in small agroforestry plots across many different countries by people who tend to be often quite poor and don't have access to regulation to technology, maybe in the way that some of the larger farmers do.
So, there's obviously challenges with dealing with one regulation that covers such different products and especially if you're exposed to multiple of them in your supply chain.
We do think that there's been a huge growth in, in, in this compliance industry that's providing fee for service solutions that are targeted to companies.
So, there is a solution for that.
You know, we don't assess the, the relative worth or value of those offers because we don't, you know, necessarily endorse offers like that, but there has been a huge growth in this sector.
There's a lot of different offers available.
So, I think for companies that have the ability to invest in that, that's probably The easiest approach.
However, there are also a number of free and open source tools for those actors that don't feel like they have the necessary cash in hand to invest in those compliance systems, including, you know, ones that have come up by, by NGOs, ones that are provided by governments, so including the EU has the Joint Research Commission's Forest Observatory for the UDR, WRI has something called Global Forest Watch, which provides free and open access data.
There's a group called TRACE, which, from Global Canopy.
That provides free and open access data to risk screening for different subnational parts of different countries for different commodities and etc.
Etc.
Research reports.
One thing that we do hear a lot about is the challenge of verifying and validating information about risk.
And how to put in place a protocol for responding to any kind of information that says there is concern or potential risk of deforestation in this particular supply chain or in this, you know, area of a country that you're sourcing from.
So, what specifically do you do as a company to follow up on that and that You're set up if you have people in the country itself, if you have boots on the ground, or if you have ability to send someone there and or if you have in-house experts that can give you some advice or if you're outsourcing it to others.
So, it's hard to come up with one response to that, but that has been 11 thing that's come up a lot.
How do you interpret legal systems, how do you interpret, different remote systems, remote sensing, information systems, etc.
One thing that we promote at WRI, along with groups like the FAO, the Food and Agriculture Organization of the United Nations, is something we call convergence of evidence.
So, not seeing different data sets from, let's say, the European Union and WRI as contradictory, but seeing them as resilience and strength.
So, the more data sets you have, the better your global view and your local view will be of what is happening.
And that means that if there are different opinions or different results from different data sets, that just means that you're getting towards a better, you know, set of, you're getting to a more granular understanding of, of the problem.
And it's not something that you have to sort of think about, as a conflict.
This says yes, it says no.
It says, OK, there may not be a problem in this particular area.
If I have 3 data sets, 2 say there's no problem, 1 says there is a problem that is better than having only 1 data set that says there is a problem, right?
So, I think we think of this as something that we should work towards jointly, not to contrast and focus our time on arguing between methodologies, but more to think of them as a richer, more resilient approach.
Hm, that makes sense, yeah.
OK, so as a final question, 5 years from now, how should we judge whether this regulation has succeeded or failed?
I think there's a few different ways to approach that.
I think one is going to be whether the EUDR is in implementation and has been seen as delivering on the level of transformation of supply chains that it's aiming to do.
So, I do think that there is, I think, some continued stress and concern that the UDR will be pushed back again, of course, as it has been two years in a row, and we're really hoping that the European Union will not continue pushing it back because at this point, there's been A huge amount of investment by companies, by countries who've put in place tracking systems put in place better for sponsoring systems by all number of, of smallholders that have tried to map their plots and provide information to their buyers.
So, if now the EUDR gets pushed back again, I think there's a huge loss of credibility for the European Union and also for any other regulatory effects they, , any other regulatory efforts they, they go for in the future.
At the same time, so one is, is it actually in implementation and, and is it working?
The second is, I think could be measured by the level of substantiated concerns and by oversight missions that the competent authorities conduct.
So, are they actually enforcing it or are they just shelving these reports and doing nothing about them?
And then the third is what, what change do we see in the countries, right?
I think that we've already before Before the EUDR is even coming into application, we're seeing huge levels of change in how people are managing information and how people are, are, are preparing for this.
So, the efforts to map, you know, millions of farmers conducted by companies, by NGOs, by UN agencies and others to help them prepare for this has been very impressive to see.
I've never seen so much change happen so quickly on the ground.
Because of any policy or company efforts.
So, that's been very impressive and I think we'll see what happens after 5 years if this becomes a new normal, if this becomes something that people just sort of accept and deal with, or if, if it's, it's continues to be a challenge and something that is generating a lot of complaint.
And then I do think that there's been a lot of concern around whether this regulation affects smallholders negatively, and I do think that there could be some future concerns there.
I have to say that some of the arguments, Aren't always factually that correct.
Like, we've heard a lot of complaints around smallholders being excluded from the market.
In some cases, smallholders are selling to the EU and others, they're not currently selling to the players that sell to the EU.
So, it's not true for all sectors in all commodities and all geographies that smallholders are are providing their products to the EU, which means that you're not really excluding them from the market if they're not selling to it now.
Could you preclude them from accessing that market in the future?
And that's maybe more of a concern is I are companies going to set up systems that essentially are simple and straightforward and maybe prioritize larger growers just because it's easier.
That could be something that we'll see in the future, whether it has an effect on the ability to develop new market access for smallholders that are currently not selling to the EU.
I think that would be one thing to watch for.
And then finally, of course, the, the last, the last, area where we'd want to see any kind of effect is if it is actually helping to The way that land use decisions are made and whether forests are continuing to be cleared for agricultural development.
And I just want to also make clear because that's something that also is, there's a lot of debate about that when it comes to the UDR and just to be clear that the EU never has claimed that this regulation will stop deforestation because they don't think of their market share as important enough to drive that global transformation.
What they have said is that they want to reduce their own Footprint on deforestation from the products that they consume.
So, I think that trying to measure the impact of the UDR by measuring global deforestation, I think is not necessarily an appropriate way forward.
Instead, I would say has the way that we source products and has the way that we make decisions about sourcing and land use decision has that changed.
Hm.
Tina, thanks for joining Finneres First today and sharing your insights.
Appreciate it.
Thank you.
