Same Regulation, Different Penalties: How Ireland and Germany Are Implementing the EUDR

The EU Deforestation Regulation applies directly in every Member State, but the penalties for breaking it do not. Each country writes its own enforcement law, names its own competent authority and sets its own sanction levels within the framework of the regulation. With application starting on 30 December 2026 for large and medium operators and traders (30 June 2027 for micro and small operators), those national laws are now arriving. Two early examples, Ireland and Germany, show what to watch.

If you want the basics of the sanction toolbox, our guides on EUDR penalties and how competent authorities monitor and penalise non-compliance cover it. This post is about the next layer: how national implementation changes your exposure.

Ireland: a detailed draft with criminal penalties

Ireland's Minister for Agriculture, Food and the Marine published the draft General Scheme of the Deforestation and Forest Degradation Bill 2026 on 12 August 2026, according to Arthur Cox. The Minister is designated as competent authority, and the Irish Examiner reports that the Revenue Commissioners handle customs controls.

The draft sets out a graduated structure:

• Summary conviction: a class A fine (up to EUR 5,000) and/or up to six months' imprisonment.
• Conviction on indictment: a fine of up to EUR 10 million, 4% of aggregate EU-wide turnover, or the economic benefit gained, and up to three years' imprisonment.
• Additional sanctions: forfeiture of products and revenues, exclusion from public procurement for up to 12 months, and a prohibition on using simplified due diligence.

This is a draft general scheme. Details may change as the bill moves through the Oireachtas, so treat the figures as the current proposal rather than settled law.

Germany: implementing act in the parliamentary process

On 12 August 2026 the German Federal Cabinet adopted implementing legislation (the Entwaldungsfreie-Produkte-VO-Durchführungsgesetz), with entry into force planned for 30 December 2026, per Polygon One's status tracker. The parliamentary process was still open at the time of writing. We have not independently confirmed the final German penalty levels, so check the enacted text before relying on any figure.

Why divergence matters

Industry is already worried about uneven enforcement. At the OFI conference in Amsterdam on 21 to 23 September 2026, speakers argued that national competent authorities must align their approaches so the market cannot route goods through the most lenient entry point (OFI Magazine). Alignment is a request, not a guarantee.

What to do now

1. Map your Member States of entry. List where you place goods on the market or where your downstream customers do, and note each competent authority.
2. Track national bills. Ireland and Germany are only two of 27 systems. Where a national law is not yet published, plan against the regulation itself.
3. Plan to the strictest regime you face. A single documented due diligence process that meets the toughest likely standard is cheaper than country-specific variants.
4. Keep records audit-ready. Competent authorities will ask for the evidence behind each statement, see record-keeping and audit readiness.
5. Review contract protection. Criminal and turnover-based exposure raises the stakes for supplier warranties, see our contract clauses guide.

The core obligations are the same everywhere. What differs is the cost of getting them wrong, and that depends on where your goods land.