What does the EUDR delay mean in practice?
EUDR Compliance for Importers
Importers are at the spotlight of EUDR Compliance, download our checklist to stay on top of your implementation journey.
The three key due diligence obligations
1. Collect supplier information
Importers must collect detailed information about their supply chain. This includes in particular the geolocation of production plots, information on producers and suppliers, the affected products, quantities as well as relevant evidence of the legality of production.
This information forms the basis for the subsequent risk assessment under the EUDR.
2. Conduct a risk assessment
Companies must verify whether products are linked to deforestation after December 31, 2020 or are associated with violations of laws in the country of origin.
For this, a structured and traceable risk assessment is required. Only products with negligible risk may be placed on the EU market.
3. Mitigate risks and submit a due diligence statement
If the risk assessment identifies a non-negligible risk, companies must take appropriate risk mitigation measures, e.g. obtaining additional evidence or information.
Subsequently, a Due Diligence Statement (DDS) can be submitted in the EU system TRACES.
What concrete steps companies must take in 2026
Common mistakes after the delay
The delay does not mean the obligation no longer applies. The clock is already ticking.
Companies that collect EUDR-relevant data too late risk supply chain disruptions at the beginning of 2027.
The responsibility lies with the importer. Early supplier engagement is crucial.
SMEs are also affected from June 2027 – with the same obligations..
Without a systematic approach and digital processes, EUDR compliance will become a bottleneck.
Achieve EUDR compliance with ease
Frequently asked questions about the EU Deforestation Regulation (EUDR)
Importers first confirm the scope according to Annex I and that they act as operators for each process step. They collect geolocation data at plot level/farm level and production/harvest dates, and then assess the risks of deforestation and legality. All non-negligible risks must be mitigated before placing products on the market.
They submit a Due Diligence Statement (DDS) in TRACES prior to marketing the goods and keep all evidence for audits for at least five years. In addition, they are required to provide their customers with the DDS reference numbers.
The EU’s TRACES system is mandatory for submitting DDS data and exchanging reference information. Companies typically combine it with a due diligence and traceability platform (e.g. osapiens HUB) to integrate suppliers, collect geodata, conduct EUDR-compliant risk assessments, and automate DDS workflows.
Geodata analysis tools like the osapiens HUB for EUDR support the deforestation assessment. Secure document archives and ERP integrations ensure auditable records and efficient data flows.
The osapiens HUB for EUDR enables companies to achieve compliance through an automated, efficient, and user-friendly due diligence process that is legally validated and minimizes manual effort.
Standard internal tools rarely meet the strict EUDR requirements. The osapiens HUB for EUDR conducts documented assessments of deforestation and legality risks for each plot and each transaction, and validates the results with geospatial evidence to confirm that the products are deforestation-free.
In addition, a complete audit trail is maintained that links products with plots, suppliers, data, and DDS reference numbers, with records kept for at least five years. Since the EUDR is constantly evolving, companies must conduct continuous monitoring to ensure they meet the latest requirements.
Therefore, the osapiens HUB for EUDR was developed in collaboration with leading legal experts.
The EUDR covers seven core commodities: cattle, cocoa, coffee, palm oil, rubber, soya, and wood. In addition, a wide range of products made from these raw materials – listed in Annex I of the regulation – also fall within the scope and must meet the requirements.
Yes, the European Parliament adopted the EUDR in April 2023, followed by approval by the Council in May 2023. The regulation (EU) 2023/1115 entered into force in June 2023.
According to the EUDR, all market participants and traders who bring the following goods to the EU market or export them from the EU must equally prove that their products do not originate from recently deforested areas or have contributed to forest degradation. This includes soya, cattle, palm oil, wood, cocoa, coffee, rubber, and some of their derivatives, such as leather, chocolate, tires, and furniture. The EUDR is intended to ensure that products consumed by EU citizens do not contribute to global deforestation or forest damage. The main objective is to stop the expansion of agricultural land for the production of the aforementioned products.
The EUDR stipulates that every company that trades in one or more of the seven listed products and imports them into the EU or exports them from the EU – with the possibility that, after review by the EU, additional products may be added to the list – must prove that its products are free from deforestation and were produced in compliance with the laws of the country of origin. Various aspects such as land use, labor, and human rights are taken into account. In addition, companies are required to submit a due diligence declaration for their products. This obligation applies regardless of whether the company is based in the EU, and covers both legal and illegal logging within and outside the EU.
The EUDR provides for clear sanctions for violations, including fines of up to 4% of a company's annual EU turnover. In addition, the affected product or the proceeds from a related transaction can be confiscated. Further sanctions include temporary exclusion from public procurement and access to public funds, temporary prohibition of placing, supplying, or exporting the affected goods or products, as well as prohibition of using the simplified due diligence procedure.
The competent authorities of each member state review the due diligence statements and associated documentation before customs clearance. The likelihood of an inspection depends on how high the risk is that the goods do not comply with the requirements. In Germany, the Federal Office for Agriculture and Food (BLE) has already been named as the "competent authority" for implementing the regulation.