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Sustainability

EUDR – Regulation on Deforestation-free Products

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Deforestation-free: 

Production of the commodity did not cause deforestation or forest degradation after 30th Dec 2020, regardless of whether the deforestation or forest degradation was legal according to the applicable legislation in the country of production.

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Legally produced: 

Production of the commodity occurred in accordance with relevant legislation of the country where the production took place.

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Due diligence: 

Commodities and products are covered by a due diligence statement (DDS)

Sustainability Commitment
Regulatory Compliance
Transparency and Responsible Forestry

Sustainability Commitment

At MM Group we believe in responsible sourcing and support the EU Deforestation Regulation (EUDR) as an important step in ensuring that companies are held accountable for their impact on the environment and society. Our commitment to sustainability goes beyond legal requirements, and we prioritise renewable raw materials, responsible resource use, and decarbonisation activities.

Regulatory Compliance

We are fully committed to complying with the EUDR and are currently in the process of implementing the new regulation to our operations. Our dedicated project team is working on adapting internal procedures to evolving regulatory guidance, implementing a compliance system, and ensuring smooth stakeholder onboarding to allow for the exchange of data as required by the EUDR. We are going to be fully compliant before the regulation comes into force on December 30th, 2025.

Transparency and Responsible Forestry

We take our responsibility to minimise our environmental impact seriously and are committed to promoting responsible forestry practices. We support the EUDR’s goals of ensuring transparency in the use of forests as a source of raw material and promoting sustainable practices.

  • See the full list of commodities in Annex I of the Regulation
  • Only products that are listed in Annex I and made of or containing a commodity listed in Annex I are subject to the Regulation.
  • Products not listed in Annex I are not subject to the Regulation, even if they contain commodities listed in Annex I. For example, soap will not be covered by the Regulation, even if it contains palm oil.
  • Products listed in Annex I that do not contain, or are not made of, a commodity listed in Annex I are not subject to the Regulation.

Annex I states that the Regulation does not apply to goods if they are produced entirely from material that has completed its lifecycle and would otherwise have been discarded as waste. Therefore, no obligation applies under the Regulation in respect of the recycled material. On the contrary, if the product contains any percentage of non-recycled material that is listed in Annex I, then it is subject to the requirements of the Regulation and the non-recycled material will need to be traced back to the plot of origin via geolocation.

Certification can support companies in risk assessment and help them verify legality and responsibility of their supply chains. However, the content of different certification schemes vary, and companies are still required to exercise due diligence even though certification can be used as supporting documentation.

The regulation does not apply to packaging material when it is used to protect another product. However, the regulation applies to packaging material when it is placed on the market as such and when it is used for special (e.g. decorative) purposes beyond protecting the product.

HS (Harmonized System) Nomenclature categorises products under international 6-digit codes. CN (Combined Nomenclature) codes contain two additional digits and are used in the European Union, especially for customs purposes. In EUDR, relevant products are determined based on CN codes listed in Annex I.