In 2020, the European Commission acknowledged that deforestation is a major driver of the global climate and biodiversity crisis, and that the EU also contributes to these crises, as the EU population consumes a significant share of products linked to deforestation. The Intergovernmental Panel on Climate Change (IPCC) has found that halting deforestation and restoring ecosystems is one of the most effective ways to reduce CO2 concentrations and thus combat climate change. In this regard, the relevant EU Regulation (EUDR) was developed and adopted, which aims to ensure that a number of key products traded and consumed in the EU and globally no longer contribute to deforestation and forest degradation. The EUDR covers palm oil, cattle, soya, coffee, cocoa, timber, rubber, and products derived from these products, such as beef, chocolate and furniture.
The EUDR therefore requires European companies importing listed products into the EU market to carry out due diligence to confirm that the products do not originate from lands that have been subject to deforestation or forest degradation after 31 December 2020. Companies must also verify that these products comply with the applicable legislation of the country of origin, including on respect for human rights and the rights of indigenous peoples in whose territories logging or other activities related to the EUDR are carried out.
As for the latter requirement, according to it, the lion’s share of wood originating from the territory of the Russian Federation should be banned from import into the EU. The EUDR entered into force in its entirety on 29.06.2023, but the specific rules and obligations should start to apply at the end of December 2024. However, on 04.12.2024, MEPs approved a one-year extension of the Regulation’s application, as well as certain exemptions from the due diligence rules provided for in the EUDR. Further, in May 2025, all 27 EU Member States, as well as major agricultural exporters such as Brazil and Indonesia, were removed from the European Commission’s list of countries with a “high risk” in the context of combating deforestation. The EC has identified only four countries as “high risk”, none of which are major exporters of the aforementioned products to the EU. Until now, it was believed that the rules set out in the Regulation should finally apply to large and medium-sized operators and traders on 30.12.2025, and to small and micro-enterprises on 30.06.2026. However, as of today, 18 EU agriculture ministers have asked the EC to postpone the entry into force of the Regulation again. Moreover, 10 EU Member States (Austria, Luxembourg, Bulgaria, Croatia, Czech Republic, Estonia, Italy, Portugal, Poland and Slovenia) are insisting on introducing a new category into the Regulation – “no risk” in relation to a potential exporting country of the products in question.
However, according to some politicians, environmentalists and independent experts (for example, from the NGO Earthsight), the introduction of such an exceptional category into the text of the Regulation will, in practice, seriously harm the EU agenda in the context of combating deforestation, and will also significantly facilitate the path of “shadow” imports of wood into the EU from third countries. After all, products covered by the Regulation are subject to rebranding and relabeling and are often accompanied by fraudulently obtained certificates of origin, which state that they were manufactured in third countries. First of all, the proposed innovation in the text of the EUDR will be fully used by suppliers of Russian and Belarusian wood. After all, wood from a country with a “no risk” category will be exempt from most checks, primarily checks on the origin of products and primary geolocation.
This will open a huge loophole that will allow timber and other goods related to deforestation to flow unhindered into the EU. As a result, this will lead to a violation of the EU’s “green policy”, successful circumvention of sanctions by Russia and Belarus, encourage unscrupulous businessmen and cause losses to responsible importing companies. At the same time, it should be emphasized that Russia and Belarus are already doing a great job of circumventing EU restrictions, even without making the aforementioned controversial changes to the EUDR. Yes, the EU introduced sanctions on timber imports from Russia and Belarus back in the spring of 2022, but despite this, smuggling and circumvention of bans continues and allows Russian and Belarusian companies to sell products worth hundreds of millions of euros despite the sanctions.
For example, during 2022-2023, there was a significant increase in timber imports from Kazakhstan to Poland, indicating schemes with re-labeling of Belarusian timber. An investigation by the NGO Earthsight found that from the moment the restrictions were introduced until October 2024 (when the latest statistics were provided), EU countries purchased birch plywood alone for a total amount of more than €1.5 billion. The material is used in the production of furniture, parquet, sports equipment and toys. Among the buyers are suppliers of the largest Polish furniture chain Black Red White and the largest manufacturer of climbing walls Walltopia. The plywood is produced in Russia and Belarus (including using prison labor), after which it is registered as produced in other countries, for example, in China, Kazakhstan, Georgia and Turkey. Every day, 22 containers of sanctioned plywood alone are imported into the EU, although other types of wood and pulp are also imported. The largest importers of plywood from Russia and Belarus are Poland, Estonia, Germany, Greece, Italy, Spain and Portugal.
At the same time, as Earthsight experts emphasize, even if plywood from Russia and Belarus were not under sanctions, its import into the EU would still be illegal, according to the EUDR, since a significant amount of Russian and Belarusian products are illegally cut down. It is needless to remind that the profits from the sale of this wood are directed to finance the Russian army and maintain the dictatorial regime in Belarus, which directly contradicts the purpose of the sanctions. In this context, Ukrainian wood producers have the potential to, at least partially, replace supplies from Russia and Belarus, however, smuggling creates unfair conditions on the EU market. In general, it is not enough to simply introduce the necessary sanctions. To obtain the desired effect, they must be strictly adhered to!