LULUCF Regulation

Objectives and scope

The EUDR promotes the use of products that are not linked to deforestation, in order to reduce greenhouse gas emissions, biodiversity loss and the EU’s global environmental footprint. It has three complementary goals:

1. Ensure that goods consumed in the EU do not contribute to deforestation or forest degradation, in Europe or elsewhere.

2. Cut carbon emissions linked to EU consumption and production of the commodities concerned by at least 32 million tonnes a year.

3. Tackle deforestation caused by agricultural expansion, and forest degradation linked to the products covered.

The Regulation applies to cattle, cocoa, coffee, oil palm, rubber, soya and wood, and to derived products such as leather, chocolate and paper. Since the 2025 simplification (Regulation (EU) 2025/2650), only operators that first place relevant products on the EU market must carry out due diligence and submit due diligence statements. Companies further down the supply chain no longer need to submit their own statements, although the first downstream operator must be registered and ensure the traceability of the commodities it uses. Micro and small primary operators submit a one-time declaration instead of a full due diligence statement.

Statements are submitted through an EU information system built on the TRACES platform. The system reopened on 3 July 2026 after technical updates, with simplified declarations for micro and small operators, API access and an updated dashboard. Products that do not meet the requirements cannot be placed on the EU market or exported, and national competent authorities are responsible for enforcement. Countries are classified according to their risk of deforestation linked to the commodities in scope.

Relevance for growing media

Wood, a key raw material for growing media, is expressly within the scope of the EUDR. The Regulation applies to products listed in Annex I that contain, have been fed with or have been made using the relevant commodities, including wood.

The Regulation also has a broader land-use dimension. Its review clause refers to a possible extension of scope to other wooded land and to other natural ecosystems, including peatlands and wetlands. These are possible future developments, but they show that the EUDR is part of an evolving framework on deforestation, forest degradation and ecosystem conversion that may continue to shape the policy context for growing media raw materials.

State of play

On 4 May 2026, the European Commission published a simplification package for the EUDR. It included a draft Delegated Act amending the product list in Annex I, updated guidance and FAQs, and a report reviewing the simplification measures adopted in December 2025. The package does not reopen the Regulation itself.

The draft Delegated Act clarifies that the Regulation does not apply to certain materials, but woody constituents of growing media remain in scope. After a public consultation and a meeting of the Member States Expert Group on 21 May 2026, the Commission made six targeted changes to the product list. It left 19 further stakeholder requests for inclusion or exclusion to the general review planned for 2030. New product categories will apply from 30 December 2027.

According to the review report, the simplification measures adopted since 2023 cut annual compliance costs for companies in scope by 75%, from an estimated EUR 8.1 billion to EUR 2.0 billion a year. The Commission has also committed to publishing two trade facilitation repositories by December 2026: one listing relevant national legislation by country of production, and one covering certification schemes for EUDR commodities.

The general review in 2030 will assess a broader scope, including a possible extension to other wooded land and to other natural ecosystems such as peatlands and wetlands (Article 34(2)).

Policy recommendations

Apply the EUDR proportionately to wood used in growing media

Wood fibre and bark used in growing media are processed and transformed materials, largely derived from the residues of other wood processing. Applying the full due diligence and geolocation regime to them adds cost without materially reducing deforestation risk.

Why it matters

Wood fibre and bark are increasingly important constituents of growing media. How the EUDR applies to them will affect costs and supply chains for producers across Europe. A proportionate approach would keep the focus on real deforestation risk without adding unnecessary burdens to materials that largely come from wood processing residues.

Legal reference: Regulation (EU) 2023/1115 of the European Parliament and of the Council of 31 May 2023 on the making available on the Union market and the export from the Union of certain commodities and products associated with deforestation and forest degradation and repealing Regulation (EU) No 995/2010.