BlogpostThe European Union Deforestation Regulation (EUDR) represents one of the most significant shifts in how businesses source and trade commodities linked to deforestation. If your company imports, exports, or trades in products like coffee, cocoa, palm oil, or timber, this regulation will fundamentally change how you operate in the EU market.
This comprehensive guide breaks down everything you need to know about EUDR requirements, from understanding which commodities are covered to implementing a compliant due diligence system in your organisation.
Quick overview: what the EUDR means for your business
Regulation (EU) 2023/1115, commonly known as the EUDR or the deforestation free products regulation, is the EU’s landmark law designed to ensure that products entering or leaving the European market do not contribute to global deforestation or forest degradation. For importers, exporters, and EU producers of certain commodities, this regulation introduces substantial new compliance obligations.
Here’s what you need to know at a glance:
- Main goal: Prevent the placement of products linked to deforestation and forest degradation on the EU market or their export from the Union
- Core obligation: All relevant products must be proven deforestation free, legal in the country of production, and covered by a valid due diligence statement before market placement or export
- Key dates for large operators and traders: Full obligations apply from 30 December 2025 (following a one-year postponement from the original timeline)
- Key dates for SMEs and micro operators: Simplified obligations with full application from 30 June 2026
- Cut-off date: Products must originate from land that was not subject to deforestation after 31 December 2020
The EUDR applies to the seven commodities of cattle, cocoa, coffee, oil palm, rubber, soya, and wood. However, the scope extends far beyond raw materials—many derived products such as chocolate, leather goods, furniture, coffee products, and rubber articles also fall under these rules.
What is the EUDR and why was it adopted?
The EUDR, formally known as Regulation (EU) 2023/1115, establishes rules on making available on the Union market and exporting from the Union certain commodities and products associated with deforestation and forest degradation. This regulation marks a significant expansion of EU efforts to address the environmental impact of global trade.
Key facts about the regulation’s background and purpose:
- The EUDR entered into force on 29 June 2023, replacing and substantially expanding the earlier EU Timber Regulation (EUTR), which focused solely on illegal logging
- The regulation aims to reduce the EU’s contribution to global deforestation, greenhouse gases emissions, and global biodiversity loss driven by agricultural expansion
- It applies equally to products placed on the EU market and those exported from the EU, ensuring a consistent standard across all trade flows
- The law introduces a strict deforestation free requirement tied to a cut-off date of 31 December 2020—meaning the land where commodities were produced must not have been subject to deforestation or forest degradation after this date
- The EUDR is a core component of the European Green Deal and supports the EU’s broader climate change mitigation and biodiversity strategies
- According to European Commission research, the EU was responsible for importing goods linked to approximately 16% of global deforestation between 2013 and 2020, making this regulation a direct response to the bloc’s environmental footprint
The regulation emerged from growing recognition that voluntary certification schemes and previous regulatory approaches were insufficient. The EU’s 2019 Communication on Stepping up EU Action to Combat Deforestation set the foundation, and following COP26 pledges and pressure from environmental organisations, the European Commission proposed the regulation on 17 November 2021. The law was adopted on 1 June 2023 after intensive negotiations to balance environmental goals with trade considerations.
Which commodities and products fall under the EUDR?
The EUDR covers seven relevant commodities and an extensive list of relevant products derived from them, all specified by CN code in Annex I of the regulation. Understanding exactly what falls within scope is essential for determining whether your business needs to comply.
The seven commodities covered by the EUDR, along with example products:
- Cattle: Live bovine animals, beef, veal, and leather products including bags, shoes, and upholstery
- Cocoa: Cocoa beans, cocoa paste, cocoa butter, cocoa powder, and chocolate products including confectionery and baked goods containing cocoa
- Coffee: Green coffee beans, roasted coffee, instant coffee, coffee extracts, and coffee-containing products
- Oil palm: Crude and refined palm oil, palm kernel oil, and products containing palm-based ingredients such as certain foods, cosmetics, and biofuels
- Rubber: Natural rubber (including latex) and a wide range of rubber articles such as tyres, gaskets, and rubber footwear
- Soya: Soybeans, soya meal, soya oil, soya lecithin, and animal feed containing soya
- Wood: Logs, sawn timber, wood panels, pulp, paper products, furniture, wooden packaging, and charcoal
The scope captures many processed goods when they contain or are manufactured from these commodities. For example, a furniture brand using tropical hardwood, a chocolate manufacturer sourcing cocoa, a coffee roaster importing beans, or a rubber goods producer using natural latex all fall within the regulation’s reach.
It’s important to note that the scope can be adjusted through future delegated acts. The European Commission has the power to add new commodities linked to deforestation or to refine the product lists. As part of amendments already adopted, printed materials were removed from scope to narrow the regulation’s coverage and reduce administrative burden on certain sectors.
Who must comply and from when? (operators, traders, SMEs)
Understanding who qualifies as an “operator” or “trader” under the EUDR is fundamental to determining your obligations. The regulation creates distinct categories with different requirements and timelines.
Operators are defined as any natural or legal person who, in the course of a commercial activity, first places relevant products on the EU market or exports them from the EU. This includes importers bringing commodities covered into the EU and manufacturers who first make products available.
Traders are those who, in the course of a commercial activity, make relevant products already placed on the EU market available on that market. This category includes distributors, wholesalers, and retailers under certain conditions.
Application dates by actor type:
- Large and non-SME operators and traders: Full EUDR obligations, including comprehensive due diligence requirements, apply from 30 December 2025. This date reflects the adopted one-year postponement from the original December 2024 deadline.
- Medium sized enterprises: The same obligations as large operators apply from 30 December 2025, though some proportionality considerations may affect implementation.
- SME and micro operators: Simplified or reduced obligations apply in certain cases, with full application from 30 June 2026. Small and micro primary operators benefit from specific easements.
- Downstream traders: Those dealing only with products already placed on the market may have reduced requirements, such as record-keeping obligations without the need to submit a full due diligence statement.
The regulation applies to:
- EU-based companies placing products on the EU market or exporting them
- Non-EU companies when they import into the EU through EU-established entities
- Any business in the value chain that acts as the first operator or as a trader making products available
If your business currently handles timber or wood products under the EU Timber Regulation (EUTR), you must transition to EUDR rules within the new timelines. The EUDR effectively replaces the EUTR with a broader and more stringent framework.
Both operators and traders bear the same obligations in terms of ensuring compliance, though the specific requirements for due diligence may differ based on position in the supply chain and company size.
Core EUDR obligations: deforestation-free, legality and traceability
At the heart of the EUDR are three interconnected requirements that operators and certain traders must satisfy before placing relevant products on the EU market or export them from the Union.
Operators must ensure that products are:
- Deforestation free
- Produced in accordance with relevant legislation of the country of production
- Covered by a valid due diligence statement submitted before market placement or export
Understanding “deforestation-free”
The deforestation free requirement is the centrepiece of the regulation. In practical terms, this means:
- No conversion of forest to agricultural use (or any non-forest use) after 31 December 2020 for any plot of land where the relevant commodity was produced
- For wood products specifically, no forest degradation as defined in the regulation—this includes conversion of primary forests or naturally regenerating forests to plantation forests or other wooded land after the cut-off date
- The definition of “forest” follows the Food and Agriculture Organization (FAO) criteria: land spanning more than 0.5 hectares with trees higher than 5 metres and canopy cover exceeding 10%
This cut-off date approach means that products derived from recently deforested land cannot legally enter or leave the EU market, regardless of whether the deforestation was legal under local law.
Understanding the “legality” requirement
Beyond being deforestation free, products must also be produced in compliance with the relevant legislation of the country of production. This includes:
- Land use rights and tenure regulations
- Environmental protection laws
- Forest management regulations
- Labour rights and worker protection laws
- Human rights protections, including the rights of indigenous peoples
- Tax and anti-corruption legislation
- Third-party rights where applicable
This dual requirement—deforestation-free and legal—means that even if production did not involve recent deforestation, non-compliance with local laws can still block market access.
Traceability requirements
To prove that products meet these standards, the EUDR mandates robust traceability through supply chains:
- Collection of precise geolocation information (latitude and longitude coordinates) for all plots of land where the relevant commodities were produced
- For larger plots, polygon coordinates with accuracy meeting the 500m x 500m standard specified in implementing guidance
- Clear documentation linking each consignment to these specific production plots
- Maintenance of supply chain records showing the chain of custody from production to market placement
These traceability obligations are enforced through the EUDR Information System, a centralised digital platform where operators must submit their due diligence statements electronically. This system replaces earlier approaches and creates a unified EU-wide compliance infrastructure.
Due diligence system under the EUDR
Operators placing relevant products on the EU market or export them must establish and maintain a documented due diligence system. This system must be operational before any covered products are traded and must be applied consistently to all relevant transactions.
The due diligence system comprises three key elements that work together to demonstrate compliance:
Information collection forms the foundation of the system. Operators must gather comprehensive data including:
- Detailed product descriptions and quantities
- Country of production identification
- Geolocation coordinates of all plots where the commodity was produced
- Production dates and harvest periods
- Supplier identification and contact details
- Evidence of compliance with the country of production’s relevant legislation
- Reference numbers linking products to supply chain documentation
Risk assessment requires operators to evaluate the probability that products in their supply chains are linked to deforestation, forest degradation, or illegality. This assessment must consider:
- The country or region risk category assigned by the European Commission
- The specific type of commodity and its deforestation risk profile
- Complexity of the supply chain and number of intermediaries
- Prevalence of deforestation or forest degradation in the sourcing region
- Available satellite monitoring data and observatory information
- Concerns raised by third parties or civil society organisations
- The robustness of supplier compliance systems
Risk mitigation measures must be implemented when the risk assessment reveals more than negligible risk. Possible measures include:
- Requesting additional documentation or certifications from suppliers
- Commissioning independent verification or third-party audits
- Utilising satellite monitoring services to verify production plots
- Conducting on-the-ground verification visits
- Adjusting sourcing patterns to avoid high-risk origins
- Implementing contractual requirements with suppliers regarding deforestation
Operators may only proceed with market placement when their risk mitigation measures have reduced the identified risk to a negligible level.
The due diligence statement must be submitted via the EUDR Information System before each consignment is placed on the market or exported. This statement includes the required information about the products, confirms that due diligence has been exercised, and provides reference numbers for tracking and enforcement purposes.
SMEs and certain traders may follow simplified due diligence procedures or rely partly on statements from upstream operators. However, all actors in the chain must maintain robust record-keeping and be able to demonstrate that products they handle are covered by valid due diligence.
Country benchmarking and risk-based controls
The European Commission will classify countries—and potentially sub-national regions—into three risk categories based on their association with deforestation and forest degradation linked to the relevant commodities. This benchmarking system directly affects how the EUDR applies in practice.
The three risk categories and their implications:
- Low-risk countries: Operators sourcing products from these countries benefit from simplified due diligence obligations. Requirements for information requirements and risk assessment are reduced, and checks by competent authorities occur at lower frequencies. The Commission’s initial list included 8 nations such as Japan.
- Standard-risk countries: This is the default category. Full due diligence requirements apply, including comprehensive information collection, detailed risk assessment, and implementation of risk mitigation measures where necessary. Most countries will fall into this category initially.
- High-risk countries: Operators face heightened scrutiny and more intensive compliance obligations. Competent authorities conduct checks at significantly higher rates, and operators may need to implement extensive risk mitigation measures including third-party audits and enhanced satellite monitoring. Countries like Indonesia and Brazil, with significant deforestation linked to commodity production, may fall into this category.
The Commission will publish and regularly update the country risk classifications, informed by multiple sources including:
- Data from the EU Observatory on deforestation and forest degradation
- National deforestation and reforestation rates
- Production trends for commodities covered by the EUDR
- Information from producer country governments
- Input from civil society and research organisations
- Bilateral cooperation agreements with producer countries
Even when sourcing products from low-risk countries, operators must still collect core information and submit due diligence statements. The simplification relates to the intensity of risk assessment and the frequency of monitoring, not the fundamental obligation to prove products are deforestation free and legal.
Approximately 15 countries, including Vietnam and Ghana, are currently negotiating bilateral arrangements with the EU to establish their benchmarking status by Q2 2026.
Setting up and maintaining an EUDR-compliant system in your company
Implementing EUDR compliance requires integrating new requirements into existing supply chain management, procurement, and sustainability processes. Companies that start early will be better positioned to meet the 2025/2026 deadlines without disruption to their operations.
Mapping your supply chains
The foundation of EUDR compliance is understanding exactly where your commodities originate:
- Identify all suppliers of commodities covered by the EUDR and trace back to the source
- Work with suppliers to obtain geolocation information for each plot or farm
- Document the chain of custody from production to your point of purchase
- Map indirect supply chain relationships where you purchase through intermediaries or traders
- Prioritise sourcing products from supply chains where traceability is already established or can be readily implemented
Developing internal procedures
Formalise your approach to meeting diligence requirements through documented procedures:
- Create standard operating procedures for information collection from suppliers
- Establish a risk assessment methodology tailored to your commodity portfolio and sourcing regions
- Define clear criteria for when risk mitigation is required and what measures to implement
- Build workflows for preparing and submitting due diligence statements
- Integrate EUDR compliance checks into procurement approval processes
Choosing tools and data sources
Select appropriate technology and information sources to support your compliance efforts:
- Geographic Information System (GIS) tools or satellite monitoring services for verifying production locations
- Supplier portals or platforms for collecting required information and documentation
- Legal documentation repositories to maintain evidence of compliance with country legislation
- Integration with systems like the EU Observatory on deforestation and forest degradation for risk information
- Databases linking CN codes to your product portfolio for scope assessment
Organisational responsibilities
Clear accountability is essential for effective EUDR compliance:
- Assign a compliance officer or team with responsibility for EUDR implementation
- Define roles for procurement, sustainability, legal, and IT functions
- Establish escalation procedures for risk decisions and non-compliance issues
- Create reporting lines to senior management for compliance status updates
Training and supplier engagement
Build capability across your organisation and supply chain:
- Train relevant staff on EUDR requirements, deadlines, and documentation expectations
- Develop supplier guidance materials explaining what data and evidence you need
- Engage key suppliers in producer countries early to secure cooperation
- Consider joint initiatives with industry peers to support smallholder suppliers who may lack digital literacy or resources
Data management
Avoid fragmented approaches by centralising compliance information:
- Implement systems to store geolocation data, supplier information, and risk assessments
- Link due diligence records to specific consignments and transactions
- Ensure data formats align with EUDR Information System requirements
- Integrate EUDR data with existing trade compliance and customs systems where possible
Ongoing maintenance and review
EUDR compliance is not a one-time exercise:
- Regularly review and update risk assessments based on new information, changing deforestation patterns, or legal developments in sourcing countries
- Maintain all due diligence records, risk analyses, and mitigation evidence for at least 5 years for potential inspection
- Monitor updates from the European Commission on country benchmarking and implementing guidance
- Periodically test your system through internal audits or engage third-party reviewers to identify gaps
- Track developments in satellite monitoring and other verification technologies that could strengthen your compliance
Enforcement, inspections and penalties
EU Member States must designate competent authorities to monitor and enforce EUDR compliance. These authorities vary by country—for example, Germany’s BfR, the Netherlands’ NVWA, or relevant customs and food safety agencies in other Member States. The European Commission supports this enforcement framework through the centralised Information System and coordination mechanisms.
Types of compliance checks
Competent authorities will conduct various forms of inspection:
- Document reviews examining due diligence statements, supporting evidence, and record-keeping
- Physical inspection of consignments at borders and ports
- On-site audits at operator and trader premises
- Remote verification using satellite data and geolocation cross-checking
- Follow-up investigations based on complaints or third-party information
Inspection intensity
The frequency and depth of checks varies based on risk:
- Products from high-risk countries face the highest inspection rates
- Standard-risk sourcing receives baseline inspection levels defined in implementing acts
- Low-risk country products benefit from reduced inspection frequency
- Operators with a track record of non compliance may face enhanced scrutiny regardless of sourcing origin
Cooperation between authorities
Enforcement involves coordination between different agencies:
- Customs authorities work with competent authorities to identify and flag non-compliant shipments at borders
- Products lacking valid due diligence statements may be detained or blocked from release into free circulation
- Information sharing between Member States enables tracking of operators across the EU market
- The EUDR Information System provides a centralised record for authorities to verify compliance
Consequences of non-compliance
Businesses that fail to meet all the requirements face significant consequences:
- Market access prohibition: Products cannot be placed on the EU market or export from the Union without valid due diligence
- Withdrawal and recall orders: Competent authorities can require removal of non-compliant products already on the market
- Financial penalties: Fines must be effective, proportionate, and dissuasive, potentially reaching up to 4% of EU turnover for serious violations—which could mean €200 million or more for major operators
- Confiscation: Non-compliant goods may be seized and cannot be sold
- Public procurement exclusion: In serious cases, businesses may be temporarily barred from EU public contracts or access to public funding
- Reputational damage: Non-compliance becomes a matter of public record, affecting consumer trust and business relationships
Practical enforcement example
Consider a scenario where a cocoa trader attempts to import a consignment without submitting the required due diligence statement to the EUDR Information System. At the border, customs authorities cross-reference the shipment against the database. Finding no valid statement, they detain the goods. The competent authority then investigates, requiring the trader to prove compliance or face fines and product seizure. Without proper geolocation data and legality evidence, the consignment cannot be released, and the trader faces potential penalties plus storage costs and supply chain disruption.
Support tools, recent amendments and next steps for businesses
The EUDR framework continues to evolve as the EU refines implementation details and responds to stakeholder feedback. Staying informed about changes is essential for businesses preparing for compliance.
Recent amendments and adjustments
Several significant changes have been adopted since the regulation’s initial publication:
- Application dates postponed: The original December 2024 deadline for large operators was extended by one year to 30 December 2025, with SME deadlines moving to 30 June 2026. This postponement followed requests from over 120 organisations and reflects implementation challenges in both the EU and producer countries.
- Simplified obligations for small primary operators: Small and micro primary operators (such as smallholder farmers in producer countries) benefit from reduced reporting and due diligence requirements to avoid disproportionate burdens.
- Printed materials removed from scope: Books and other printed paper products were removed from Annex I, narrowing the regulation’s coverage and reducing administrative requirements for publishers and printers.
- Clarified definitions and guidance: The Commission has published additional guidance on geolocation requirements, the operation of the Information System, and transition arrangements from the EUTR.
Available support tools and resources
Several EU-level tools support EUDR implementation:
- EUDR Information System: The centralised platform for submitting due diligence statements, expected to be fully operational ahead of the application dates
- EU Observatory on deforestation and forest degradation: Provides data on global deforestation trends, satellite monitoring information, and supports country benchmarking decisions
- European Commission guidance documents: Official FAQs, implementation guides, and explanatory materials available through the Commission’s environment portal
- National competent authority resources: Each Member State’s designated authority provides country-specific guidance and contact points for queries
- Industry initiatives: Sector bodies and multi-stakeholder platforms offer shared tools, training, and supplier engagement support
Recommended next steps for your business
With application dates approaching, businesses should act now to prepare:
- Conduct a gap analysis: Compare your current practices against EUDR requirements to identify where changes are needed in information collection, risk assessment, and documentation
- Prioritise high-risk commodities and supply chains: Focus initial efforts on products and origins where deforestation risk is highest or traceability is weakest
- Engage suppliers in producer countries: Begin dialogue with suppliers to secure geolocation data, legality documentation, and commitment to compliance. For example, work with cocoa suppliers in Côte d’Ivoire—where 70% of production may face compliance challenges—to implement traceability solutions
- Plan technology and system upgrades: Assess whether your current IT infrastructure can handle due diligence information flows, integrate with the EUDR Information System, and maintain required records
- Allocate resources and assign responsibilities: Budget for compliance costs (estimates range from €2,000 to €23,000 annually for SMEs according to Copenhagen Economics research) and ensure clear ownership of EUDR implementation
- Monitor regulatory developments: Track Commission announcements on country benchmarking lists, implementing acts, and guidance updates
- Consider industry collaboration: Join sector initiatives or certification schemes that align with EUDR requirements to share the burden of supply chain verification
Looking ahead
The EUDR represents a fundamental shift in how the EU addresses deforestation through trade policy. Projections suggest the regulation could help prevent 14 million hectares of deforestation by 2030, with corresponding benefits for climate and biodiversity. For businesses, early preparation is not just about avoiding penalties—it’s about securing deforestation free supply chains that meet evolving consumer expectations and contribute to sustainability goals.
Rabobank analysis indicates that up to 50% of supply chain configurations may need adjustment by 2028 to achieve compliance. Companies that begin this work now will be better positioned than those who wait until deadlines loom.
The regulation may also serve as a template for similar measures globally, with discussions ongoing in the United States and other major markets. Investing in EUDR compliance today could therefore provide a foundation for meeting future regulatory requirements elsewhere.
Early, structured preparation will reduce compliance risk and position your business to meet the 2025/2026 deadlines. The time to begin mapping your supply chains, engaging your suppliers, and building your due diligence system is now. Those who act decisively will navigate these requirements smoothly while creating more sustainable, resilient operations for the future.