The EU Deforestation Regulation at THIMM
Statement by THIMM, October 2025
What is the EUDR?
With the new EU Deforestation Regulation, the EU is setting clear due diligence obligations for companies. They are required to ensure that their products are deforestation-free - meaning that no new forest areas were cleared or damaged during the production of the product.
The European Deforestation Regulation (EUDR) aims to ensure that certain raw materials and products made from them are only made available on the European Union market if they have been produced in a deforestation-free manner and in accordance with the applicable legal requirements.
The scope of the regulation covers products made from wood, rubber, cocoa, coffee, palm oil, soy, as well as cattle and products derived from them.
What is new (Status 01/2026)
As part of the trilogue procedure, amendments to the timing and content of the EUDR were agreed on December 16, 2025, which have an impact on THIMM's obligations.
For companies of THIMM's size, the date of application of the regulation is postponed to December 30, 2026. In addition, under the current legal situation, THIMM will be reclassified as a downstream operator within the meaning of the EUDR.
Impact on THIMM
Based on this classification, THIMM is no longer required to review due diligence statements (DDS) from our suppliers or to prepare its own due diligence statements. The receipt and storage of reference numbers is only necessary in cases where THIMM acts as a direct downstream market participant of a first distributor of EUDR-relevant goods. The identification of the suppliers affected by this is currently being reviewed.
In addition, the European Commission has announced that it will develop further details and simplifications for the practical implementation of the EUDR by April 30, 2026, at the latest. THIMM is continuously monitoring regulatory developments and will evaluate and properly implement new mandatory requirements after they become legally binding.
Regardless of the current scope of legal obligations, THIMM remains committed to the principle of ensuring responsible and legally compliant supply chains. Our customers will continue to be informed transparently about significant changes and their impact on their cooperation with THIMM.
Do you have any questions?
THIMM Group
+49 5551 703 0
mail@thimm.de