EU Regulation 2023/1115 enters into force. Cut-off date for deforestation fixed at 31 December 2020.
EU Deforestation Regulation (EUDR)
The EU Deforestation Regulation prohibits placing seven in-scope commodities on the EU market without verified deforestation-free sourcing, legal production documentation, and a submitted Due Diligence Statement. Enforcement begins 30 December 2026 for large and medium operators and traders, and 30 June 2027 for micro and small undertakings.
ENFORCEMENT DEADLINE
The EUDR clock is ticking
69
Days
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6
Hours
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37
Minutes
Time left until the EUDR enforcement deadline for large and medium operators and traders.
Close your EUDR compliance gaps, step by step.
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EUDR for Importers Checklist
Close your EUDR compliance gaps, step by step.
Get the free EUDR for Importers Checklist and build an audit-ready evidence trail without slowing down your business.
Who is affected by EUDR?
EUDR applies to any company placing cattle, cocoa, coffee, palm oil, soya, wood, rubber, or products derived from them on the EU market, regardless of size. Company size only affects the timing: large and medium operators and traders must comply from 30 December 2026, while most micro and small undertakings have until 30 June 2027 (with the exception of those already in scope of the previous EUTR, who must comply from 30 December 2026 regardless of size).
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Cattle
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Rubber
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Wood
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Palm Oil
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Soy
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Coffee
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Cocoa
Best-In-Class EUDR Compliance Goes Beyond DDS Submission
EUDR compliance is often equated with only one deliverable: the due diligence statement (DDS) submitted in the EU Information System TRACES. But the DDS is only the visible output of a wider due diligence system, and it is the system that authorities can inspect. Operators must be able to show how they collected information, assessed and mitigated risk, and verified that each plot was deforestation-free and legally produced, and to explain the rationale behind each of those decisions. They must also keep the evidence and produce it on request. Best-in-class compliance therefore goes well beyond filing: it means a documented process, traceable material flows, plot-level legality checks, and the ability to respond when third parties raise concerns about a supply chain.
The three due diligence obligations every first operator must meet
EUDR due diligence applies in full to first operators (companies that first place an in-scope product on the EU market, whether by import or domestic production). It is structured around three sequential obligations, each of which feeds directly into the next.
Establish plot-level traceability
For each in-scope shipment, operators must collect the geolocations, harvesting dates, and legality documentation. Geodata must come from the actual producer or farm.
Assess risks
Using the collected geodata, first operators must verify that no deforestation occurred on the relevant plots after 31 December 2020, and that production complied with applicable national laws.
Mitigate and submit a Due Diligence Statement
Where the risk assessment identifies deforestation or legality concerns, first operators must take mitigation measures before placing the product on the EU market. Once mitigation is complete and risk is assessed as negligible, the operator submits a Due Diligence Statement via EU TRACES, generating a reference number that must be passed to all downstream recipients.
Establishing an EUDR Due Diligence System
Turn EUDR requirements into a repeatable, explainable process. Collect supplier data, production origins and supporting evidence. Check for gaps, assess deforestation and legality risks, and resolve any non-negligible risk before goods enter the market. Define who owns each step, submit Due Diligence Statements where required, and keep decisions documented.
Preparing for EUDR Audits
Be ready to explain the decision behind each shipment. Connect supplier documents, production plots, risk assessments and relevant Due Diligence Statements. Show what was checked, which risks were identified and how they were resolved. Keep evidence accessible so your team can respond to authority requests without rebuilding records from scratch.
Assessing EUDR Legality & Chain of Custody
Verify that commodities were produced legally and can be traced to their origins. Check relevant land-use rights, permits and supporting documents. Follow material through collection, trading and processing, including mixed lots. Investigate missing records and conflicting information. Certification can support the assessment, but does not replace EUDR due diligence.
Responding to EUDR Substantiated Concerns
Act fast when credible evidence points to potential non-compliance. Anyone can raise a substantiated concern, from NGOs and local communities to competitors and authorities, so be ready to respond fast with the right information. Identify affected suppliers and shipments, review the original assessment and collect additional evidence. Depending on your obligations, withhold goods and inform authorities and customers. Document the investigation, corrective action and evidence supporting the final decision.
Regulation timeline
EUDR Made Easy
A Structured Approach for SMEs and Mid-Market Companies:
Join our EUDR Made Easy webinar series and get practical guidance on due diligence documentation, risk assessment, and EUDR implementation for SMEs and mid-market companies ahead of the December 2026 deadline.
Frequently asked questions (FAQs)
EUDR covers seven commodity groups: cattle, cocoa, coffee, palm oil, rubber, soy, and wood. Derived products listed in Annex I of the regulation also fall within scope, including leather, beef, chocolate, furniture, paper, tires, and palm-oil-derived ingredients. The regulation applies to both imported and EU-produced goods placed on the EU market, as well as products exported from the EU.
Deforestation-free means no forest was converted to agricultural use on the sourced land plots after 31 December 2020. Proving it requires plot-level geodata, specifically GPS coordinates or polygons of specific farms and parcels, cross-validated against satellite-derived forest-cover data. Country declarations and certifications alone are not sufficient under the regulation.
Products contracted today will need a Due Diligence Statement at the point of placing on the EU market. For companies whose sourcing cycles run 12 to 18 months from origin to shelf, geodata collection must run in parallel with purchasing decisions already in progress.
The regulation requires member states to set penalties that are effective, proportionate, and dissuasive. The benchmarks written into the regulation include fines of up to 4% of annual EU-wide turnover for the most serious infringements, confiscation of products and revenues, and temporary exclusion from public procurement. Non-compliant shipments in high-risk corridors face detention and seizure at customs.
A first operator is any company that first places an in-scope product on the EU market, whether by import or domestic production. There is no public registry for operator roles. A company can only determine whether a supplier is a first operator by directly confirming whether that supplier imports or first places the product on the EU market and whether they issue a Due Diligence Statement in EU TRACES.
A first operator must conduct full due diligence: collecting plot-level geodata, conducting deforestation and legality risk assessments, and submitting a Due Diligence Statement via EU TRACES before the product is placed on the market.
A trader, defined as any company making an in-scope product available on the EU market after it has already been placed there by an operator, is not required to conduct full due diligence. Traders must collect, document, and store the DDS reference numbers received from upstream first operators and make that documentation available to competent authorities on request.
Any company placing an in-scope product on the EU market or exporting it from the EU counts as an operator. SMEs carry the same due diligence obligations as large operators. Company size affects enforcement timing only: large operators and traders must comply from 30 December 2026, and SMEs from 30 June 2027.
For each in-scope product, first operators must collect plot-level geodata for every sourcing location, evidence of legal production under the laws of the country of origin, and the relevant CN codes and countries of origin. Geodata must come from the actual producer or farm. Logistics partners and freight forwarders cannot supply it on the producer's behalf.
The European Commission assigns sourcing countries one of three risk classifications: negligible, standard, or high risk. The classification determines the level of due diligence required: negligible-risk countries allow for simplified due diligence, while standard and high-risk countries require full due diligence. The Commission published its first official country classification in May 2025.
The competent authorities of each EU member state review Due Diligence Statements and associated documentation before customs clearance. The likelihood of an inspection depends on the assessed risk that the goods do not comply with EUDR requirements. In Germany, the Federal Office for Agriculture and Food (BLE) has been named as the competent authority for implementing the regulation.
Traders sourcing from SME suppliers are not required to conduct EUDR due diligence on products placed on the EU market before the SME's date of application. They must collect and be able to verifiably document that the products were placed on the EU market before 30 June 2027.
The geodata and supplier information collected for EUDR due diligence covers land use, environmental compliance, and supply chain traceability at plot level. The same supplier data layer is relevant to CSDDD due diligence obligations and Scope 3.1 carbon reporting, both of which require verified supplier and origin data. Companies managing EUDR, CSDDD, and carbon reporting simultaneously can structure a single supplier data collection exercise to cover all three obligations.
A standalone deforestation tool covers plot-level risk assessment against satellite data and stops there. EUDR compliance requires collecting geodata from suppliers, conducting legality assessments, managing DDS submissions via EU TRACES, passing reference numbers to downstream recipients, and retaining audit-ready records for a minimum of five years. A compliance platform connects each of these steps into a single workflow rather than requiring separate tools and manual handoffs between them.
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