The European Union regulation on deforestation-free products (EUDR) represents a policy innovation with important implications for the governance of global commodity chains. We discuss the risks and limitations of this policy derived from an ex-ante assessment of the robustness of its theory of change. For doing so, we use insights from the literature on zero-deforestation commitments and other private standards in value chains and from trade and deforestation patterns in three relevant producer countries (Brazil, Colombia and Indonesia). Despite the potentially positive symbolic effect in mobilizing a global agenda for combating deforestation, the EUDR faces several drawbacks and risks associated with three of its constitutive features: To be demand-oriented, having the value chain as the unit of intervention and holding a high degree of unilateralism. We conclude that to be effective in curbing tropical deforestation, the Regulation must be complemented with international cooperation aiming to strengthen national policies with a territorial approach, as well as social movements addressing the underlying causes of forest loss and human rights violations in the territories where it takes place.