The EU Deforestation Regulation (EUDR), explained

The EU Deforestation Regulation (EUDR), Regulation (EU) 2023/1115, bans selling cattle, cocoa, coffee, oil palm, rubber, soya, wood and listed products made from them on the EU market, or exporting them, unless they are deforestation-free, legally produced and covered by a due diligence statement or, for some small producers, a simplified declaration.¹ After two postponements, its core obligations apply from 30 December 2026 for large and medium operators and from 30 June 2027 for most micro and small operators.²

When does the EUDR apply?

The EUDR entered into force on 29 June 2023,¹ and its obligations were first due to apply from 30 December 2024.⁴ They have been postponed twice. Dates in force on 11 October 2026:

Dates can change: check the European Commission's EUDR page for updates.

Which products does the EUDR cover?

Examples from Annex I, which lists products by customs code, after the 2026 update:¹⁶

Printed books and newspapers left the list in 2025.² The 2026 update removed cattle hides and leather, conveyor belts, aircraft and car seats and soya for sowing, and excluded samples, waste and packaging used only to carry another product.⁶ Products produced before 29 June 2023 are not covered, with transitional rules for timber.¹²

What does "deforestation-free" mean?

• Forest: more than 0.5 hectares with trees taller than 5 meters and canopy cover above 10%, or trees able to reach those thresholds, excluding land mainly in agricultural or urban use.¹
• Deforestation: conversion of forest to agricultural use, whether caused by people or not.¹
• Deforestation-free: produced on land not deforested after 31 December 2020. For wood, also harvested without causing forest degradation after that date.¹

Products must also be legal under the country of production's laws on land use rights, environmental protection, forest rules, third parties' rights, labor rights, human rights, free, prior and informed consent, and tax, anti-corruption, trade and customs.¹

Who has to do what under the EUDR?

• Operators place a covered product on the EU market for the first time, or export it. They must exercise due diligence, submit a due diligence statement through the EU Information System beforehand and pass its reference number down the chain.¹²
• Downstream operators and traders sell or export products already covered by a statement. They keep supplier and customer details for five years; the first in the chain also keeps the statement reference numbers. Non-SMEs among them must register in the Information System.²
• Micro or small primary operators are individuals and small firms in a low-risk country selling what they grow, harvest or raise there. They file a one-time simplified declaration and may give a postal address instead of geolocation.²

Producers outside the EU have no direct obligations unless they sell on the EU market themselves, but EU buyers may ask them for information such as where products were grown.⁷

Due diligence in three steps

1. Collect information: product, quantity, country of production, the geolocation of every plot and the production date, suppliers, customers, and verifiable evidence that the product is deforestation-free and legal.¹
2. Assess risk: using criteria such as the country's risk category, forests and Indigenous peoples in the area, corruption, supply chain complexity and the risk of mixing.¹
3. Mitigate risk: unless it is negligible, for example with more information or independent audits. A product with more than negligible risk may not be placed on the market.¹

Geolocation means latitude and longitude to at least six decimal places. Plots above four hectares need a polygon; for cattle, every establishment where the animals were kept counts.¹ Operators that establish that all their sourcing is from low-risk countries, with negligible risk of mixing, may skip risk assessment and mitigation.¹

Country risk, checks and penalties

The EU classifies every country as low, standard or high risk. The high-risk countries are Belarus, North Korea, Myanmar and Russia; all 27 EU member states and the United States are low risk.⁸ Brazil, Indonesia, Malaysia, Côte d'Ivoire and the Democratic Republic of the Congo are standard risk.⁹ National authorities must check at least 1% of relevant companies each year for low-risk sourcing, 3% for standard risk and 9% for high risk.²

Member states set penalties, which must include fines with a maximum of at least 4% of total annual EU-wide turnover, confiscation of products and revenues, up to 12 months' exclusion from public procurement and funding and, for serious or repeated breaches, a temporary ban on selling or exporting.¹ Anyone can submit substantiated concerns about a company to the authorities.²

Is your supply chain EUDR-ready?

1. Map every product you buy, sell or export against Annex I by customs code, including the 2026 changes.
2. Decide your role for each product flow, and whether you are an SME.
3. Confirm your date: 30 December 2026, or 30 June 2027 if you were a micro or small undertaking or natural person by 31 December 2024 and your products are not EU Timber Regulation timber.
4. Register in the EUDR Information System if your role requires it.
5. Collect geolocation for every plot (polygons above four hectares) or cattle establishment, with production dates.
6. Check each plot for deforestation after 31 December 2020 and, for wood, forest degradation.
7. Gather evidence of legal production, including land rights, labor and human rights, and free, prior and informed consent.
8. Assess risk using the country classification and the regulation's criteria, and mitigate anything above negligible.
9. Submit due diligence statements before placing on the market or exporting, pass reference numbers on and keep records for five years.
10. Review your due diligence system at least once a year. Operators that are not SMEs must also report on it publicly every year.¹

Background: causes of deforestation, palm oil, solutions.

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