The EU Deforestation Regulation at THIMM
Statement by THIMM, October 2025
What is the EUDR?
With the new EU Deforestation Regulation, the EU is establishing due diligence obligations for companies. Companies are required to ensure that their products are deforestation-free, i.e. that no forest areas have been newly used through deforestation or forest degradation during the manufacture of the products. The European Deforestation Regulation (EUDR) aims to ensure that certain commodities and products made from them may only be made available on the market of the European Union if they are deforestation-free and have been produced in accordance with the applicable legal requirements. The scope of the Regulation covers products made from wood, rubber, cocoa, coffee, palm oil, soya and cattle as well as products derived from them.
What is new?
The European Commission has further specified the practical application of the EUDR. The text of the Regulation remains unchanged; the date of application for larger companies remains 30 December 2026. Micro and small enterprises have a longer preparation period until 30 June 2027. In particular, roles in the supply chain, simplified obligations for downstream operators, requirements for reference numbers and individual clarifications regarding product scope and use of the EU Information System have been specified.
Impact on THIMM
Based on the latest amendment by the European Commission, THIMM is to be classified as a downstream operator. It follows that, according to the current understanding, THIMM is not obliged to
create its own due diligence statement for goods that have already been placed on the market in compliance with the EUDR. Likewise, there is no general obligation to independently retrace or verify the complete due diligence carried out by upstream operators. THIMM continues to regularly review the supply chain and its position within it. In relevant cases, transmitted reference numbers or declaration identifiers would be duly recorded and retained. Further legally binding requirements or clarifications by the European Commission are being continuously assessed and, where necessary, incorporated into internal processes. Irrespective of the statutory obligations, THIMM remains committed to ensuring responsible, transparent and legally compliant supply chains. We will continue to inform our customers transparently about material changes and their impact on cooperation with THIMM.
Do you have any questions?
THIMM Group
+49 5551 703 0
mail@thimm.de