The German Federal Government approved the draft General Administrative Regulation for the national implementation of the EU Deforestation Regulation, EUDR, on October 7, 2026. The regulation aims in particular to simplify implementation in forestry and domestic primary production, make greater use of existing administrative structures and ensure that EUDR controls are carried out more consistently across Germany.
Germany’s preparations for the national implementation of the EUDR have entered a new phase. At the Federal Cabinet meeting held on October 7, 2026, the draft “General Administrative Regulation on the Act Implementing the EU Regulation on Deforestation-Free Products” was included among the items adopted without debate.
Prepared by the Federal Ministry of Agriculture, Food and Regional Identity, BMLEH, the regulation does not seek to change the EUDR’s core obligations. Instead, it focuses on how the competent authorities in Germany will apply and enforce those obligations.
For this reason, the October 7 decision represents a separate process from Germany’s previously discussed EUDR implementation law. While the implementation law addresses issues such as competent authorities, inspections, sanctions and penalty provisions under national law, the new administrative regulation provides greater detail on how the obligations will be applied in practice.
A More Practical Approach for Domestic Producers
In previously published implementation documents, the German government stated that the General Administrative Regulation was intended particularly to reduce additional administrative burdens in the agriculture and forestry sectors.
One of the most notable areas concerns simplifications related to the submission of geolocation information in certain circumstances.
The EUDR relies heavily on the traceability of the areas where products are produced or raw materials are sourced. However, Germany’s proposed administrative framework aims to provide greater scope for the use of existing national registers and address information for certain domestic primary producers.
This is intended to allow existing administrative records to be used instead of requiring the same information to be recreated for every transaction, particularly for small-scale domestic producers.
However, this approach does not mean that the EUDR’s fundamental traceability system is being removed. The regulation is instead intended to define how implementation will function within Germany and how low-risk domestic production can be monitored more efficiently.
Collective Declarations for Forestry Associations
One of the most notable parts of the regulation for Germany’s forestry sector concerns provisions allowing collective reporting through forestry associations and joint organizations.
A significant proportion of Germany’s privately owned forests consists of small and fragmented holdings. Forestry associations therefore play an important role in jointly managing production, sales and administrative processes for large numbers of forest owners.
The new administrative regulation aims to make greater use of these structures in reporting processes under the EUDR.
This approach could allow certain procedures to be carried out collectively rather than requiring numerous small forest owners within the same supply chain to repeat similar processes independently.
The important distinction is that this simplification does not constitute a general exemption from EUDR obligations. The fundamental requirement to demonstrate that a product is deforestation-free, has been produced in compliance with the relevant legislation of the country of production and meets the necessary traceability requirements remains in place.
Adjustments Also Planned for Medium-Sized and Large Companies
The draft is not limited to small forest owners or agricultural producers.
The German government also foresees implementation adjustments for medium-sized and large enterprises whose activities are only partly related to products and raw materials covered by the EUDR.
This is particularly relevant for municipalities engaged in forestry activities, public enterprises or companies operating across a wide range of business areas.
The approach is based on considering not only the overall size of the company but also the nature and scope of the activity that falls within the EUDR.
These adjustments do not, however, change the products covered by the EUDR. For wood and wood products, the product scope defined under EU legislation remains unchanged.
Two Separate EUDR Processes Are Advancing in Germany
Germany’s EUDR preparations currently involve two main regulatory processes that are moving forward in parallel but serve different purposes.
The first is the national EUDR implementation law, which was approved by the Federal Government in August and submitted to parliament. This legislation is intended to determine which institutions will carry out inspections in Germany, define their powers and establish administrative measures and sanctions applicable in the event of infringements.
The draft submitted to the German Bundestag foresees a role for the Federal Office for Agriculture and Food, BLE, together with competent authorities at state level within the control system.
The second regulation is the General Administrative Regulation approved by the cabinet on October 7. This text focuses particularly on the practical operation of primary production and national control mechanisms within Germany.
The two regulations should therefore not be treated as the same legal process. One establishes the framework for powers, sanctions and national legal infrastructure while the other provides detail on the administrative implementation of that system.
The Core Requirements of the EUDR Remain Unchanged
The simplifications being prepared by Germany do not remove the fundamental structure of the EUDR at European Union level.
In order for products covered by the EUDR to be placed on the EU market or exported from the EU, they must essentially:
be deforestation-free,
have been produced in compliance with the relevant legislation of the country of production
and provide the required traceability and compliance information in accordance with EUDR requirements.
For wood and wood products, the criterion relating to forest degradation occurring after December 31, 2020 also remains an important element of EUDR assessment.
The main purpose of Germany’s administrative regulation is not to redefine these requirements but to make greater use of existing public registers and national administrative structures in domestic control and documentation processes.
December 30, 2026 Is Approaching
The timing of the regulation is also important for the industry.
Under the current EU timetable, the EUDR will apply to large and medium-sized enterprises from December 30, 2026.
For most micro and small enterprises, the application date is set for June 30, 2027. However, December 30, 2026 remains applicable to micro and small enterprises that were previously covered by the EU Timber Regulation, EUTR.
Following amendments introduced at the end of 2025, the European Commission also introduced certain simplifications to the EUDR implementation model.
In particular, changes were made to the obligations of companies operating further downstream in the supply chain and a one-time simplified declaration mechanism was introduced for certain micro and small primary producers.
Germany’s new administrative regulation stands out as one of the complementary steps adapting these EU-level changes to the national implementation system.
The Final Text Will Be Important for the Wood Industry
As one of Europe’s largest markets for wood processing, furniture and forest products, Germany is among the countries closely monitored by the industry because of its national choices regarding EUDR implementation.
The cabinet decision taken on October 7 provides an important indication that administrative burdens could be reduced, particularly for German forest owners and forestry associations.
For companies, however, the decisive factor will be the regulation’s final legal and administrative form.
The industry will closely monitor which companies will be able to benefit from simplifications relating to geolocation data, what conditions will apply to collective declarations submitted through forestry associations and how the adjustments for medium-sized and large enterprises will function in practice.
For now, the emerging picture suggests that Germany is attempting to make national EUDR implementation more manageable through existing registration systems, risk-based controls and shared administrative structures without changing the regulation’s environmental objectives.