What is EUDR? What Japanese businesses need to know about EU Deforestation Regulations

The European Union (EU) is introducing new requirements that will affect many companies trading with Europe. The EU Deforestation Regulation (EUDR) is designed to prevent products linked to deforestation from being sold within the EU market.

For Japanese exporters shipping eligible products to customers in Europe, and for Japanese importers sourcing regulated goods from the EU, understanding EUDR requirements is becoming increasingly important. Failure to comply could result in customs delays, shipment holds, penalties, or restricted market access.

This guide explains what EUDR is, which products are affected, and what Japanese businesses need to do when exporting to or importing from the EU.

What Is the EU Deforestation Regulation (EUDR)?

The regulation on deforestation-free products, otherwise known as EUDR, is a landmark law introduced under the European Green Deal to ensure that products sold in or exported from the European Union do not contribute to deforestation or forest degradation.

The regulation replaces the EU Timber Regulation (EUTR) and significantly expands the scope of products and supply chains that must demonstrate compliance.

Under EUDR, companies placing regulated products on the EU market must be able to prove that:

• The products are deforestation-free
• The products comply with applicable local laws in the country of production
• A Due Diligence Statement (DDS) has been submitted through the EU Information System

For Japanese companies exporting to Europe, this means greater transparency and traceability requirements across supply chains.
 

Why EUDR Matters for Japanese Exporters

Japan maintains strong trade relationships with the European Union across industries such as:

• Automotive manufacturing
• Rubber and tire production
• Wood and paper products
• Food and beverage manufacturing
• Packaging materials
• Consumer goods

Many Japanese companies export finished products containing regulated commodities, even if those commodities were sourced from other countries.

For example, a product exported from Japan to the EU may fall under EUDR if it contains:

• Natural rubber used in tires or industrial components
• Wood used in furniture, packaging, or paper products
• Coffee or cocoa ingredients in food and beverage products
• Palm oil derivatives used in manufacturing

Companies selling to customers in Europe should determine whether their products fall within the scope of EUDR and whether additional documentation may be required before shipment.

Which Products Are Covered by EUDR?

EUDR applies to seven key commodities and their derived products:

• Cattle
• Wood
• Cocoa
• Coffee
• Palm oil
• Soy
• Rubber

Examples of affected products include:

• Tires and rubber components
• Paper and paper packaging
• Wooden furniture
• Construction materials
• Chocolate and cocoa products
• Coffee products
• Leather goods

Only products listed in Annex I of Regulation (EU) 2023/1115 and made from these commodities are subject to the regulation.

Because many Japanese manufacturers use imported raw materials in global production networks, it is essential to verify whether exported products contain regulated commodities.

What Does 'Deforestation-Free' Mean?

To comply with EUDR, products must come from land that was not deforested after 31 December 2020.

Businesses must be able to trace raw materials back to their place of origin, which may include:

• Farms
• Plantations
• Forest plots
• Production sites

Supporting documentation must demonstrate that the raw materials were not sourced from land converted from forest to agricultural use after the cut-off date.

This traceability requirement is one of the most significant compliance challenges for global supply chains.

Who Must Comply with EUDR?

Operators

Businesses that place regulated products on the EU market for the first time or export them from the EU as part of a commercial activity.

Traders

Businesses that make regulated products available within the EU market after they have been placed on the market.
 

Both B2B and B2C transactions are covered by the regulation.

For Japanese exporters, the EU-based importer may often be responsible for submitting the Due Diligence Statement. However, European customers may request extensive supply chain documentation from their Japanese suppliers to support their compliance obligations.

As a result, Japanese exporters should prepare to provide product traceability and sourcing information when requested by EU customers.

What Information Is Required for the Due Diligence Statement (DDS)?

To comply with EUDR requirements, companies must complete three key steps.

1. Collect Supply Chain and Origin Information

Businesses must gather and maintain information including:

• Geolocation data for production areas
• Product quantity and description
• Production dates
• Supplier information
• Documentation proving products are deforestation-free

2. Conduct a Risk Assessment

Companies must assess whether:

• Products comply with local laws
• There is a risk of deforestation in the supply chain
• Information provided by suppliers is complete and reliable

The assessment process should be documented and retained for audit purposes.

3. Mitigate Identified Risks

If risks are discovered, businesses must implement corrective measures, such as:

• Additional supplier verification
• Independent audits
• Enhanced documentation requirements
• Alternative sourcing strategies

Companies should retain compliance records for at least five years.

Which Products Are Exempt?

EUDR does not generally apply to:

• Products produced before 29 June 2023
• Second-hand products
• Products made entirely from recycled materials
• Non-commercial consumer-to-consumer shipments

However, businesses should verify product-specific requirements before shipping.

Impact on Shipping and Customs Clearance

EUDR compliance will increasingly become part of the customs clearance process for eligible shipments entering the EU.

Shipments that do not meet the required documentation standards may face:

• Customs delays
• Additional inspections
• Goods being held at the border
• Financial penalties
• Potential restrictions on future EU market access

For many Japanese exporters, providing accurate compliance information before shipment will be crucial to avoiding disruptions.

How Japanese Businesses Can Prepare

Companies exporting to Europe should consider the following steps:

• Identify whether exported products fall within the scope of EUDR
• Review raw material sourcing and supplier traceability processes
• Discuss EUDR requirements with EU customers and importers
• Establish procedures for collecting supplier documentation
• Seek advice from customs, legal, or sustainability specialists when necessary
• Ensure required DDS information is available before shipment

Early preparation can help avoid costly disruptions once enforcement begins.

How DHL Express Japan Can Support

DHL Express Japan supports companies trading with the European Union by helping ensure shipments move through customs as smoothly as possible.

For products subject to EUDR requirements, customers should provide the Due Diligence Statement (DDS) Reference Number (DDN) before shipment.

If products qualify for an exemption, the relevant TARIC exemption code should be provided to DHL prior to customs clearance.

DHL can help customers:

• Understand shipping documentation requirements
• Identify potentially affected products
• Facilitate customs processing
• Support import and export data requirements
• Navigate evolving trade compliance requirements

While DHL does not validate DDS submissions or determine product eligibility, providing complete and accurate information in advance can help reduce customs clearance delays.

Frequently Asked Questions (FAQ)