ANALYSIS ON CONTINUED POLICIES BETWEEN THE EU AND NIGERIA

EUDR / Anti-Deforestation Regulation — Current Developments and Trajectories 

New developments & clarifications.

The EU is in the process of establishing country risk classifications through an Implementing Regulation (EU 2025/1093) that will inform the application of stricter due diligence requirements to various origin countries. Below, the category of the countries according to the risk level will be low risk (the simplification of due diligence will still be required, however, with the basic information, geolocation, etc.). Countries in the standard ones or in the higher risk group will have stricter checks and requirements (full risk assessment, mitigation). In the meantime, the EU declared one more one-year postponement of the complete implementation of the anti-deforestation law. Environment Commissioner raised an alarm that the information systems (IT infrastructure to manage registration, volume of data etc.) is not prepared to support the entire load.

Regulation on Deforestation-free products - Environment

The start date of compliance (when large operators are concerned) was December 30, 2025, although under trade pressure and internal issues, the EU is looking to postpone it. According to industry participants (e.g. agribusiness, commodity traders), delaying will sabotage regulatory certainty and forest protection ambitions.The EUDR is currently in effect and the full requirements will be binding on most market participants starting Dec 30, 2025, micro/ small business are subject to some obligations, but these become binding in phases up to after June 30, 2026.

The EU insists that the risk classification system will be dynamic (i.e. the classification of countries will depend on the monitoring and may be changed with time and on the alterations of the deforestation tendencies, changes in data, etc.).

Nestle, others warn EU law delays are endangering forests worldwide | Reuters

Nigeria is an example of suppliers of the EUDR-covered commodities (cocoa, timber products, wood, rubber, etc.) .As an example, cocoa exports by Nigeria to the EU are high (in the Africa environment, Nigeria was exporting cocoa at a tune of approximately 782 million dollars as at last reports).

 Nigeria’s cocoa exports surge to US$$782M as industry prepares for EU Deforestation rules | Food Business Middle East & Africa 

Service companies (e.g. SGS, SGS Expands IMPACT NOW Services with New EU Deforestation Regulation (EUDR) Verification ) are also expanding to be of assistance in EUDR verification, certification, compliance, traceability, to enable exporters to prepare in advance.

The country risk classification regime developed by EU can offer some assistance to the lower risk countries (assuming that Nigeria was classified by as such) by allowing the full due diligence to be less demanding. Nigeria would however require plausible on-ground information, forest surveillance, police and disclosure to achieve low risk status. Due to the reaction of the trade partners and operational issues, a controversy is being actively discussed within the EU (and by trading partners) regarding the compromise between enforcement and flexibility.

 Implications to the EU and Nigeria. 

For Nigeria:

● Trade risk and pressure of access to market: Nigerian cocoa, wood, rubber, and timber derivatives exporters have the risk of the EU refusing to accept their goods unless they can prove the absence of deforestation in their supply. This may translate to revenue loss, image tarnishment and diversion of trade.

● Compliance cost and capacity: A significant number of exporters (smallholder farmers in supply chains, particularly SMEs) might have resource constraints, lack of data infrastructure, mapping, lack of clarity in the law, lack of access to satellite images, or institutional assistance to comply with due diligence demands.

● Incentive to institutional change: Nigeria might have to hasten its own forest monitoring, land use mapping, chain-of-custody systems, legal enforcement of forest laws, transparency of forest data and support services to suppliers. Potential benefit in case of low risk classification: In case Nigeria would be classified as a low-risk, the regulatory burden (risk assessment, mitigation) would be reduced, which can help to make it cheaper and less frustrating. However, that will be subject to compliance with some standards of forest governance, data transparency, and compliance.

For the EU:

● Striking a balance between the enforcement and external stability: EU must make sure that its strict enforcement would not lead to supply chain contraction, backlash in terms of trade and the allegations of protectionism and overburdening third world economies.

● Conditionality / aid instruments uptake: To be credible and fair, EU might be forced to think about capacity-building aid, technical assistance, grants, and transitional flexibility (particularly in supplier countries with lower income). Reputation and credibility of climate risks: In case EU procrastinates excessively or dilutes rules under pressure, the critics can claim that the EU is abandoning its green commitments or it is undermining climate ambitions.

● Regulatory complexity and regulatory cost: the systems used in the EU (IT, registries, verification, audits, cross-checks across member states) should be resilient and able to scale; failure to implement them or to withstand overwhelming data volumes is a significant operational risk.