EU
Deforestation-free
Regulation
A game-changer for supply chain transparency and traceability
L’Oréal has long understood that protecting forests means protecting our future.
For over a decade, we’ve worked to build deforestation-free supply chains, set ambitious traceability and certification goals, and drive industry-wide transformation. From our Zero Deforestation policy (2014) to our updated Forest Policy (2025), halting forest loss is not new — it’s in our DNA.
It’s a redefinition of the playing field, pushing the industry towards more transparency, stronger partnerships, and shared accountability.
We see this as an opportunity to accelerate our shared journey towards a more sustainable future— together.
Let’s turn regulatory challenges into collective impact!
What is the EUDR?
This regulation aims to stop products linked to deforestation or forest degradation from being made available on the EU market or being exported from it.
If you’d like to better understand the difference between these two notions – deforestation and forest degradation – feel free to explore the infographic: “Sourcing Timber Sustainably”.
It applies to 7 forest-risk commodities : palm oil, cocoa, coffee, soy, wood, rubber and cattle, and to over 300 derived products derived from these commodities (like paper, cardboard, packaging, etc.), identified by their customs codes (Combined Nomenclature – CN codes) in Annex 1 of the regulation.
What does the EUDR require?
What does the EUDR require?
Under the EUDR, traceability to the origin plots of land is mandatory. If the origin is unknown or cannot be clearly traced, the operator cannot demonstrate compliance with the regulation. This means:
- Even if the product is certified, full traceability and due diligence is still required for EUDR compliance.
- The product cannot be placed on the EU market unless all due diligence criteria are met, including geolocation.
- The burden of proof lies with the operator to show that no deforestation or degradation occurred after 31 December 2020.
Under the EUDR, each shipment or batch of in-scope products placed on the EU market or exported must be covered by a Due Diligence Statement (DDS).
- A single DDS can cover multiple shipments, but only if they come from the same production batch — with parcels and risks clearly assessed in the DDS.
- Where a due diligence statement covers multiple batches/shipments, this additional complexity may increase the risk of non-compliance for the operator.
The level of scrutiny and required due diligence varies depending on the risk benchmark assigned to the country by the European Commission:
- Low-risk countries (e.g., France, USA, Australia)
- Standard-risk countries (e.g., Brazil, Indonesia, Cameroon)
- High-risk countries (e.g., Russia, Myanmar, North Korea)
This benchmark may be subject to change over time.
To check the latest classification of a country and stay up to date, please refer to the official:
European Commission Country Benchmark.
💡 It should be noted that on 9 July 2025, the European Parliament adopted a resolution calling on the Commission to review the Country Risk Benchmark.
In light of this resolution, it is possible that the Commission may update this benchmark in the coming months.
Even when sourcing exclusively from low-risk countries, operators must still comply with all EUDR obligations. This includes ensuring full traceability to the plot of land, legal harvesting, and no deforestation or forest degradation after the cut-off date. The main difference is that simplified due diligence and a lower inspection rate may apply — but compliance remains mandatory.
Who is responsible?
What are the risks?
- Reputational:
Companies that fail to comply may be publicly listed by the EU — not great for your brand image.
- Financial:
Non-compliance can lead to fines of up to 4% of your EU turnover.
- Operational:
Missing or incomplete data can lead to blocked shipments, delayed approvals, and major disruptions in your supply chain.
- Legal:
In some cases, breaches may even lead to criminal sanctions.
L’Oréal requires full compliance for all batches of:
- Palm-, soy-, cocoa-based raw materials
- Packaging (paper, cardboard)
- POS (paper, cardboard or wood-based point-of-sales materials)
⚠️ You will be asked to provide compliance information for every batch of in-scope products sold to L’Oréal.
What about recycled and certified materials?
To support our sustainable sourcing goals and facilitate EUDR compliance, L’Oréal strongly encourages the use of:
(For Packaging and Point of Sales materials)
- These are out of scope of the EUDR but still need to meet L’Oréal’s sustainability standards.
- Example: recycled paper-based packaging, made from 100% recycled fibers, certified FSC Recycled.
Any non-recycled component remains subject to EUDR obligations.
In short, choosing certified recycled inputs reduces your exposure to EUDR requirements — and supports circularity at the same time.
- These can help demonstrate risk mitigation.
- Example: materials with strong chain-of-custody certifications (e.g. FSC, RSPO SG, ISCC+ SG).
Even if materials are 100% FSC-certified, certification alone is not sufficient to meet EUDR requirements. Certifications can help demonstrate good practices and reduce risk, but operators must still provide full traceability to the plot of origin, proof of legality, and evidence of no deforestation.
In short: FSC supports compliance, but it cannot replace the mandatory Due Diligence Statement (DDS).
L’Oréal’s EUDR expectations from Suppliers
Each batch of product must have its own Due Diligence Statement (DDS)
The EUDR also applies to materials produced within the EU / in low-risk countries
FSC certification is not enough for EUDR compliance
Ending deforestation takes collective effort.
L’Oréal works hand-in-hand with its suppliers and their own upstream partners to build transparent and responsible sourcing chains — through traceability, due diligence, certification, and data sharing.
Full EUDR compliance is required for every in-scope batch.
⚠️ All information in this module is accurate as of October 2025.
The regulation may evolve — stay informed!
👉 This infographic is for informational purposes only and does not replace legal advice. Suppliers should consult their own legal teams or advisors regarding their specific obligations under the EUDR.
Here are some resources on the EUDR. Stay tuned for any update:
Thank you for reading!
