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 operators and traders, and 30 June 2027 for SMEs.
Next deadline:
30 December 2026: large operators and traders must have Due Diligence Statements filed for every in-scope shipment.
Purchases falling under EUDR are already being contracted today. The products you are sourcing now must meet the regulation's requirements at the point of import or placing on the market.
Regulation timeline
What the regulation requires
The EU Deforestation Regulation prohibits placing cattle, cocoa, coffee, palm oil, soya, wood, rubber, and their derived products on the EU market unless three conditions are met: deforestation-free sourcing with no forest conversion after 31 December 2020, legal production under the laws of the country of origin, and coverage by a Due Diligence Statement.
Operators must collect plot-level geodata, assess country and product risk, and submit a Due Diligence Statement via EU TRACES before goods are placed on the market.
EUDR obligations by role: operators, traders, and SMEs
The EUDR distinguishes between two categories of market participant: operators and traders. The obligations each carries differ, and the distinction determines whether a company must conduct full due diligence or fulfill a lighter set of documentation requirements.
Operator
An operator is any company that places an in-scope product on the EU market for the first time, whether by import or by domestic production.
The first operator in a supply chain carries the full due diligence obligation: 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. The DDS reference number generated at submission must be passed to all downstream recipients.
Trader
A trader is any company that makes an in-scope product available on the EU market after it has already been placed there by an operator. Traders are not required to conduct full due diligence.
They must collect, document, and store the DDS reference numbers received from upstream partners, and make that documentation available to competent authorities on request.
Company size
Company size affects enforcement timing, not the substance of the obligation.
Large operators and traders must comply from 30 December 2026.
SMEs, defined as companies meeting at least two of the following thresholds: maximum 250 employees, maximum €50 million turnover, maximum €43 million balance sheet total, must comply from 30 June 2027.
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.
Collect plot-level geodata, legality evidence, and CN codes for every in-scope product
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, not from logistics partners or freight forwarders.
Assess deforestation and legality risk against every sourced plot
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. The European Commission published its first official country risk classification in May 2025, assigning sourcing countries as negligible, standard, or high risk.
Mitigate non-negligible risk and submit a Due Diligence Statement via EU TRACES
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.
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.