EU Deforestation Regulation (EUDR) — Regulation (EU) 2023/1

Do my supply chains for coffee, soya, palm oil or wood pass the EU deforestation cut-off — and what happens at customs if they don't?

Any operator placing cattle, cocoa, coffee, oil palm, rubber, soya or wood products on the EU market must file a due diligence statement proving deforestation-free origin by 30 December 2026 — non-compliance risks fines of at least 4 % of annual EU-wide turnover and a market ban [Art. 25(2)].

Short Answer

Regulation (EU) 2023/1115 prohibits placing on the EU market, making available or exporting seven commodity groups — cattle, cocoa, coffee, oil palm, rubber, soya and wood — unless the products are deforestation-free (cut-off: 31 December 2020), comply with the legislation of the country of production and are covered by a due diligence statement [Art. 3]. Operators must collect geolocation data for every plot of land, carry out a risk assessment and, where risk is non-negligible, apply mitigation measures before submitting a due diligence statement through the EU information system [Art. 8, Art. 9, Art. 10, Art. 11]. Competent authorities must check at least 9 % of operators sourcing from high-risk countries and 3 % from standard-risk countries each year [Art. 16(8), Art. 16(9)]. The Regulation was significantly amended by Regulation (EU) 2024/3234 and Regulation (EU) 2025/2650, which deferred the application date and introduced a simplified regime for micro and small primary operators in low-risk countries [Art. 4a].

Who is affected

Any natural or legal person who, in the course of a commercial activity, places relevant products (Annex I) on the EU market, makes them available or exports them — including operators, downstream operators and traders [Art. 2(15), Art. 2(15b), Art. 2(17)]. There is no turnover or employee threshold: the obligation applies regardless of company size, though micro and small primary operators in low-risk countries benefit from a simplified declaration regime [Art. 4a]. Non-EU operators trigger the obligation for the first EU-based person who makes the product available on the market [Art. 7].

Deadline

30 December 2026 for operators and non-SME downstream operators and traders; 30 June 2027 for operators who are natural persons or micro/small undertakings established by 31 December 2024 [Art. 38(2), Art. 38(3)]. Timber products produced before 29 June 2023 remain under the old Timber Regulation (EU) No 995/2010 until 31 December 2029 [Art. 37(2)].

Risk

Fines of at least 4 % of the operator's total annual EU-wide turnover, calculated to exceed the economic benefit gained [Art. 25(2)(a)]. Additional penalties include confiscation of products and revenues, temporary exclusion from public procurement for up to 12 months, temporary market and export bans for serious or repeated infringements, and a ban on using simplified due diligence [Art. 25(2)(b)-(f)]. Final judgments against legal persons are published by the Commission with the company name and penalty amount [Art. 25(3)].

Proof

Legal status

• In force
• as of 2026-04-17
• Consolidated version of 26.12.2025 (002.001)

Primary sources

• EUR-Lex — Full text of the legal act
• European Commission — Deforestation — EU deforestation-free supply chain policy

What to do now

Legal / DPO

•Map every relevant commodity and product in your portfolio against Annex I and classify your role as operator, downstream operator or trader to determine due diligence versus record-keeping obligations [Art. 2(15), Art. 2(15b), Art. 2(17), Art. 4, Art. 5].
•Assess whether micro or small primary operators in your supply chain qualify for the simplified declaration regime in low-risk countries and document that assessment, because misclassification exposes you to full due diligence requirements [Art. 4a, Art. 2(15a)].
•Prepare for mandatory publication of enforcement judgments including company name and penalty amount — ensure your board understands that non-compliance creates public reputational risk beyond the fine itself [Art. 25(3)].

Compliance

•Establish a due diligence system with documented risk assessment and mitigation procedures, reviewed annually, and appoint a compliance officer at management level if you are not an SME [Art. 12(1), Art. 11(2)(a)].
•Collect and retain geolocation data (latitude/longitude with at least six decimal digits; polygons for plots above four hectares) for every plot of land producing the relevant commodity, for a minimum of five years [Art. 9(1)(d), Art. 9(1)].
•Report publicly and annually on your due diligence system, including risk assessment conclusions, mitigation measures and any indigenous peoples consultations, if you are not an SME or natural person [Art. 12(3), Art. 12(4)].

IT / Security

•Integrate with the EU information system (Article 33) to submit due diligence statements electronically and receive reference numbers — the system must be operational before any product can legally enter the market [Art. 4(2), Art. 33].
•Build data pipelines capable of ingesting, validating and storing polygon-level geolocation data per shipment, linked to supplier identities, and retain all records for at least five years with audit-trail integrity [Art. 9(1)(d), Art. 12(5)].
•Implement automated country-risk lookups against the Commission's benchmarking list (low/standard/high) to flag shipments from high-risk origins before customs declaration, as check rates are 9 % for high-risk vs. 1 % for low-risk countries [Art. 29, Art. 16(8)-(10)].

Product / Engineering

•Audit every product containing cattle, cocoa, coffee, oil palm, rubber, soya or wood derivatives against the Annex I product list and trace each ingredient to the plot of land where it was produced — products that cannot be traced are non-compliant by definition [Art. 3, Art. 9(1)(d)].
•Verify that all relevant commodities were produced on land not subject to deforestation after 31 December 2020, and that wood was harvested without inducing forest degradation after that date — this is the hard cut-off with no grandfathering [Art. 2(13)].
•Communicate due diligence statement reference numbers or declaration identifiers to every downstream operator and trader in your supply chain so they can fulfil their own record-keeping obligations [Art. 4(7), Art. 5(3)].

Key Terms

Relevant commodities: The seven commodity groups covered by the EUDR: cattle, cocoa, coffee, oil palm, rubber, soya and wood [Art. 2(1)].
Deforestation: The conversion of forest to agricultural use, whether human-induced or not. Forest is defined as land spanning more than 0.5 hectares with trees higher than 5 metres and canopy cover above 10 % [Art. 2(3), Art. 2(4)].
Due diligence statement: An electronic declaration submitted through the EU information system confirming that the operator exercised due diligence and found no or only negligible risk of non-compliance with Article 3 [Art. 4(2)].
Operator: Any natural or legal person who, in the course of a commercial activity, places relevant products on the market or exports them, excluding downstream operators [Art. 2(15)].
Downstream operator: Any natural or legal person who, in the course of a commercial activity, places on the market or exports relevant products made using relevant products already covered by a due diligence statement or simplified declaration [Art. 2(15b)].
Geolocation: The geographical location of a plot of land described by latitude and longitude coordinates with at least six decimal digits; for plots above four hectares (except cattle), polygons describing the perimeter are required [Art. 2(28)].
Forest degradation: Structural changes to forest cover through conversion of primary forests or naturally regenerating forests into plantation forests or other wooded land, or of primary forests into planted forests [Art. 2(7)].
Negligible risk: The risk level at which, after full assessment and appropriate mitigation, there is no cause for concern that a product does not comply with the deforestation-free and legality requirements of Article 3 [Art. 2(26)].

Frequently Asked Questions

Which commodities and products does the EUDR cover?

Seven commodity groups: cattle, cocoa, coffee, oil palm, rubber, soya and wood, plus all products listed in Annex I that contain, have been fed with or have been made using those commodities [Art. 1(1), Art. 2(1), Art. 2(2)]. This includes derived products such as chocolate, leather, furniture, printed paper, tyres and biodiesel.

What is the deforestation cut-off date?

31 December 2020. Products must be produced on land that has not been subject to deforestation after that date; wood must have been harvested without inducing forest degradation after that date [Art. 2(13)].

When does the Regulation start to apply?

The substantive obligations (Articles 3-13, 16-24, 26, 31, 32) apply from 30 December 2026 for operators and non-SME downstream operators and traders. For operators who are natural persons or micro/small undertakings established by 31 December 2024, the date is 30 June 2027 [Art. 38(2), Art. 38(3)]. These dates reflect the deferral introduced by Regulation (EU) 2024/3234.

What geolocation data must operators provide?

Operators must provide latitude and longitude coordinates with at least six decimal digits for each plot of land. For plots larger than four hectares (except cattle), polygons describing the perimeter are required. For cattle, geolocation refers to all establishments where the animals were kept. Micro or small primary operators may substitute postal addresses [Art. 9(1)(d), Art. 4a(5)].

How does the country benchmarking system work?

The Commission classifies countries or parts thereof as low, standard or high risk based on deforestation rates, governance and enforcement capacity [Art. 29]. The classification determines the intensity of competent authority checks: 1 % of operators for low-risk, 3 % for standard-risk and 9 % for high-risk countries [Art. 16(8)-(10)]. It also determines whether operators may use simplified due diligence [Art. 13].

What is the simplified regime for micro or small primary operators?

Micro or small primary operators established in a low-risk country who produce and place their own commodities on the market may submit a one-time simplified declaration instead of a full due diligence statement. They receive a declaration identifier and are exempt from the full risk assessment and risk mitigation steps [Art. 4a]. This regime was introduced by Regulation (EU) 2025/2650.

What happens to timber products already produced before the Regulation's cut-off?

Timber and timber products produced before 29 June 2023 that are placed on the market from 30 December 2026 remain subject to the old Timber Regulation (EU) No 995/2010 until 31 December 2029. From that date, they must comply with Article 3 of the EUDR [Art. 37(2), Art. 37(3)].

Assessment Factors & Checklist

Premium

Start 7-day free trial

Questions for Your Lawyer

Premium

Start 7-day free trial

Conclusion & Summary

Premium

Start 7-day free trial

Detailed analysis with source links.

Schalten Sie die KI-Analyse frei — mit markierten Fundstellen und direkten Links zu EUR-Lex. 7 Tage kostenlos testen.

Start 7-day free trial →

Keine Kreditkarte heute. Kündigung jederzeit.