Draft Act on amending certain acts in connection with the implementation of solutions for combating deforestation and forest degradation

Polish draft act implementing EUDR – what awaits entrepreneurs after 30 December 2025?

In May 2023, the European Union adopted Regulation 2023/1115 (EUDR), a breakthrough in environmental responsibility in the global supply chain. The regulation aims to reduce deforestation and forest degradation by requiring due diligence for companies placing certain goods on the EU market or exporting them from the EU.

Poland has just started the implementation phase of these provisions at the national level. The government's legislative work list includes a bill marked with the number UC101, which is to supplement EU regulations with key procedural and institutional solutions. What does this mean in practice for entrepreneurs?

EUDR – what does the EU regulation regulate?

The EUDR Regulation covers seven product groups: cattle, cocoa, coffee, oil palm, rubber, soy and timber, as well as any derived goods included in Annex I. From 30 December 2024, traders will not be able to place these products on the market or export them without prior due diligence procedures.

The basic requirement is to submit Due Diligence Statement (DDS) to the competent national authority – a document confirming that the product:

does not come from areas deforested after December 31, 2020,
was legally obtained in accordance with the law of the country of production,
is fully traceable in the supply chain.

The regulation is directly applicable in EU countries, however, it requires supplementation in terms of institutional structures, control procedures, procedures for submitting declarations, monitoring and sanctions – and this is where the role of national law comes in.

What does the UC101 project regulate?

The draft act amending the act on the Environmental Protection Inspectorate and certain other acts (UC101) is intended to define how Poland will enforce the provisions of the EUDR. It includes, among others:

designation of competent authorities to supervise individual goods,
DDS declaration submission procedure and its update,
mode of carrying out the inspection,
monitoring non-compliance risk in trade,
Documentation transfer mode, exchange of information and technical advice,
possibility of suspending trade in goods and taking interim measures,
corrective actions and sanctions in case of violations.

Appointed inspectors: who will enforce the regulations?

The project envisages the division of competences between specialized industry inspections:

Environmental Protection Inspection – wood and wood products,
Trade Inspection – rubber and its derivatives,
IJHARS – coffee, cocoa, soy and palm oil,
Veterinary Inspection – cattle and derived products.

Each body will be entitled to conduct inspections, request documentation, and decide to temporarily suspend trade in products that do not meet the requirements.

Practical consequences for entrepreneurs

The entry into force of the UC101 project means that in 2025, companies will have to have a due diligence system, including, among others:

traceability of goods to the production plot (geolocation),
risk assessment and countermeasures,
documented analysis of compliance with country of origin regulations,
regularly updating data and responding to new information.

In the event of an audit, the inability to prove due diligence may result in blocking of admission to trading, financial sanctions or corrective actions. This applies to both importing and exporting companies.

Co dalej?

At the moment, the UC101 project is at the stage of legislative announcement, the full content of the act has not been published yet. However, it is worth preparing for the upcoming obligations now:

audit your own supply chain for deforestation risk,
implement traceability procedures and DDS systems,
start a dialogue with non-EU suppliers who may not be familiar with EUDR requirements,
monitor legislative work and updates on the RCL website.

Summary

The EUDR regulation and the Polish UC101 project are changing the rules of the game for many industries. From 2025, just having certificates is not enough - it will count the real ability to prove that a product has not contributed to deforestation. For importers, this is a new regulatory challenge, but also a potential competitive advantage – a transparent supply chain is the future of sustainable international trade.

If you want to stay up to date on how to prepare your company for EUDR and adapt your systems to due diligence requirements, follow our profile and subscribe to our newsletter. In subsequent publications, we will discuss practical aspects of implementing EUDR in Poland, including documentation templates, audit procedures and communication strategy with non-EU suppliers.