The increasing deforestation of tropical and boreal forests is closely linked to the global trade in commodities such as beef, palm oil, timber and soy. In order to reduce deforestation-related greenhouse gas emissions and protect biodiversity, the European Union will regulate trade in goods that contribute to deforestation in the future. Online retailers, marketplace operators and brands that trade products made from these raw materials are directly affected. In the following article, we explain the legal framework, describe affected product groups and discuss requirements, certifications and challenges. Find out what you should prepare for and how JTL-Wawi can support you.
What is the EUDR (EU Deforestation Regulation)?
EU Regulation 2023/1115 (Deforestation Regulation) will apply from December 30, 2025 for large and medium-sized companies and from June 30, 2026 for smaller traders. The aim is to ensure that products placed on the EU market are not associated with deforestation after December 31, 2020. The regulation covers raw materials such as cattle, wood, cocoa, soya, palm oil, coffee and rubber, as well as products derived from these such as leather, chocolate, tires and furniture.
The companies concerned must submit a due diligence declaration for each batch. This confirms that the product is deforestation-free, complies with the legislation of the country of production and is fully traceable. Anyone placing products on the EU market or exporting them must know the geographical coordinates of the agricultural parcel and carry out a risk analysis. Simplified requirements apply to products from countries that the EU classifies as “low risk”.
Products may only be imported or exported to the EU if they are deforestation-free, have been produced legally and are accompanied by a due diligence declaration. The regulation provides for sanctions, including fines of up to 4 percent of EU turnover, confiscation of goods or exclusion from public sales orders.
The EU regulation on deforestation-free supply chains (EUDR) is currently the most important legal framework that entails specific obligations for many of you as retailers. At the same time, you should keep in mind that there are other regulations that are similarly aimed at transparency and responsibility in supply chains:
Since January 1, 2024, the LkSG has required companies with 1,000 or more employees to comply with human rights and environmental due diligence obligations in their supply chains. This includes the establishment of a risk management system, regular risk analyses, the adoption of a policy statement, preventive and remedial measures as well as complaints procedures and detailed documentation. The LkSG is monitored by the federal authority BAFA and can impose fines for violations. Although the law is primarily aimed at human rights and the environment, its due diligence obligations overlap with the requirements of the EUDR.
The EU is currently negotiating the Corporate Sustainability Due Diligence Directive (CSDDD). The directive is set to apply from 2027 and will oblige companies to address human rights and environmental risks along the entire value chain. It will probably cover companies with 500 employees or more and extend the obligations of the LkSG. The CSDDD has not yet been finally adopted, but retailers should align their risk management systems with it.
Product groups affected
The EUDR covers seven commodity groups and many derived products. The following categories are particularly relevant for traders:
Not all derived products are affected; for example, packaging that is used exclusively for protection is not covered by the regulation.
Obligations under the EU Deforestation Regulation
Traceability and data
Companies must record the exact geo-coordinates of the agricultural parcels from which the raw materials originate. This data is entered into an EU digital platform, which is used to submit a due diligence declaration. This contains information on the product chain, the countries of origin, the result of the risk analysis and any mitigation measures taken. Retailers must keep the unique reference code of the declaration in their business records and pass it on to customers; downstream companies may only purchase products with a valid reference number.
Risk analysis and due diligence
ECommerce retailers must check whether the products they sell are linked to deforestation or forest degradation. This includes:
- Risk assessment according to country and supplier-specific factors: the respective country is assigned a risk rating by the EU (low, normal or high). Low-risk countries (e.g. EU member states) allow for simplified due diligence procedures, while high risk countries (e.g. Belarus, Russia) require strict controls.
- Mitigation measures for identified risks, e.g. satellite monitoring, independent on-site audits or supplier changes.
- Documentation obligations: You must store all evidence (geodata, risk analyses, supplier information) for five years. The LkSG provides for similar documentation and reporting obligations.
Differences for retailer types
The EUDR distinguishes between “operators” and “distributors”. Operators are companies that supply or export relevant products to the EU market for the first time; distributors purchase these products and distribute them further. Market participants have a full duty of care. Depending on the size of the company, distributors must check the reference number of the due diligence declaration and document buyer/supplier information for five years.
Relevant certifications
Certification programs can serve as proof of sustainable forest management and legal origin, but do not automatically meet the EUDR requirements. Online retailers should use them as a supplement:
FSC certification identifies paper, wood and other products that come from responsibly managed forests. The FSC works with online marketplaces such as Amazon’s Climate Pledge Friendly program to make it easy for customers to find FSC-certified products.
Challenges and recommendations for online retailers
Complexity of supply chains
Many brands and marketplaces source their goods indirectly via retailers, wholesalers and logistics service providers. The required geodata and supplier information is often not available. You should therefore pay attention to the following:
- Mapping of suppliers: Identify and categorize all suppliers, ingredients and production facilities. Where possible, work closely with manufacturers and extend supplier contracts to include EUDR obligations.
- Close data gaps: Use traceability tools to collect geodata; request GPS coordinates of farms and plantations via satellite or directly from the producer.
- Pilot projects: Start with individual products or product groups in order to adapt processes and IT systems.
Competition and reputation
Companies that offer transparent, deforestation-free products at an early stage can differentiate themselves positively. Certifications such as FSC or PEFC and participation in initiatives such as Amazon’s Climate Pledge Friendly create visibility.
EUDR compliance and implementation with JTL-Wawi, JTL-WMS and JTL-Plan&Produce
While some companies use additional specialized tracing and due diligence tools, with JTL-Wawi you can implement all core requirements of the EUDR directly – from the recording of reference numbers to complete traceability in shipping.
With JTL-Wawi you have a practical solution at hand to efficiently meet the requirements of the EUDR:
- Batch management: When goods are received, the EUDR reference number provided by the supplier can be entered as the batch number.
- Warehouse link: Each batch is permanently linked to the warehouse stock so that no data is lost.
- Traceable shipping: The appropriate batch is automatically assigned during shipping. This ensures complete documentation of which customer has received which reference number.
- Document printing function: Reference numbers can be printed on delivery bills and passed on directly to the next stage of the supply chain.
Traceability also plays a central role within your own warehouse: With JTL-WMS, you can manage batch numbers to the exact location and track where each batch is currently located at any time. This ensures traceability not only externally, but also within the warehouse process itself.
In addition, the EUDR also affects retailers who produce or process materials themselves – for example in the production of foodstuffs that contain cocoa, for example. In JTL Plan&Produce*, each production item is assigned its own batch after production is complete. At the same time, all processed production components – such as different types of wood – can be tracked via their individual batches afterwards.
Example: If you use special wood for the legs of a chair, each of these components has its own batch, which you can view later via your production sessions.
Result: With the combination of JTL-Wawi, JTL-WMS and JTL-Plan&Produce*, retailers and producers create complete traceability – from goods receipt and warehouse management to production and delivery. This allows you to reliably fulfill the legal documentation requirements of the EUDR and be optimally prepared for official inspections.
*as of 01.12.2025
Future outlook and preparation
By the end of 2025 at the latest, online retailers must fully trace products made from affected raw materials and ensure that they have been produced without deforestation and in compliance with the law. The catalog of affected raw materials can be expanded. At the same time, further regulations are on the horizon: the EU CSDD will introduce more comprehensive due diligence obligations for human rights and environmental protection along the entire value chain.
Retailers should take the following steps:
Conclusion
The EU regulation on deforestation-free supply chains marks a paradigm shift for the trade in raw materials that drive global deforestation. For online retailers, this means significant requirements in terms of traceability, risk analysis and documentation. Certifications such as FSC and PEFC as well as specialized traceability tools can facilitate implementation. Companies that act now not only minimize liability risks, but also position themselves as pioneers for sustainable eCommerce and benefit from the increasing demand for environmentally friendly products.
The regulation affects all companies that place on the market or export raw materials (e.g. wood, cocoa, coffee, palm oil, soy, rubber or cattle) or products made from them in the EU – including online retailers that sell such goods.
The regulation will apply to large and medium-sized companies from December 30, 2025, and to small and micro-enterprises from June 30, 2026.
Traders must submit a due diligence declaration confirming that their products have been produced legally and without deforestation. This also includes knowing the geographical coordinates of the production areas.
Violations can be punished with fines of up to 4% of EU turnover, the confiscation of goods or exclusion from public sales orders.
With batch management in JTL-Wawi, you can record EUDR reference numbers when goods are received, link them to stock levels and track them during shipping. The numbers can also be automatically printed on delivery bills using the document printing function.
Not necessarily. While some companies use additional digital tools, JTL-Wawi, JTL-WMS and JTL-Plan&Produce already cover all the essential requirements of the EUDR for trade and production.
Sources:
ihk-muenchen.de
ihk-bonn.de
ihk.de
bmas.de
environment.ec.europa.eu
wko.at
fsc.org
pefc.org
