EUDR: what the EU Deforestation Regulation asks of you, and from when

EUDR is the EU Deforestation Regulation. “Legally produced” means produced legally in the product’s country of production (Art. 3Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 3Click opens the article on EUR-Lex.). The statement is filed by whoever first places the product on the EU market; everyone after them keeps a paper trail. Where a business outside the EU places the product, the first EU business that makes it available also files its own statement (Art. 7Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 7Click opens the article on EUR-Lex.).

Which products are on the list

EUDR reaches only the products listed in its Annex I, by customs code, and only where they contain, were fed with or were made using one of seven commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood (Art. 2(1)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 2, point 1Click opens the article on EUR-Lex., Art. 2(2)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 2, point 2Click opens the article on EUR-Lex.). The list as it stands on 5 October 2026, in the products an online shop meets most:

Each change in that table has a date. The printed-products line (chapter 49) was deleted by Regulation (EU) 2025/2650Regulation (EU) 2025/2650, amending the EU Deforestation RegulationThe whole regulationClick opens the law on the EU Publications Office., Art. 1(26)Regulation (EU) 2025/2650, amending the EU Deforestation RegulationThe whole regulationClick opens the law on the EU Publications Office., which entered into force on 26 December 2025. Commission Delegated Regulation (EU) 2026/2102, in force since 18 September 2026, deleted raw hides and skins, tanned or crust hides and leather of cattle (4101, 4104, 4107), conveyor belts (4010), other articles of vulcanised rubber (4016); cut the retreaded-or-used-tyres heading (4012) down to tyre treads; narrowed soya beans to those not for sowing; replaced the whole wooden-seat heading with a list that leaves out aircraft and motor-vehicle seats; and added the “used products and second-hand products” exclusion to most wood lines and three rubber lines. It added soluble coffee, frozen cattle tongues, soap and a list of palm-oil derivatives, each marked “This provision shall apply from 30 December 2027”.

The same act cut four things out of the whole list: samples “of negligible value and quantity” used only to solicit orders; products used up or destroyed in examination, analysis or tests; bamboo, rattan “and other materials of a woody nature”; and, for wood, packing “used exclusively to support, protect or carry another product made available on the market or exported and presented with that product”. A paper shipping box around your product is therefore not a listed product; a paper box you sell on its own is. Goods made entirely from material that had completed its lifecycle and would otherwise have been discarded as waste are outside too (Annex I, introductory text).

“Deforestation-free” means the commodity was produced on land not deforested after 31 December 2020, and for wood, harvested without forest degradation after that date (Art. 2(13)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 2, point 13Click opens the article on EUR-Lex.). A product whose commodity was produced before 29 June 2023 is outside the Regulation altogether (Art. 1(2)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 1, paragraph 2Click opens the article on EUR-Lex.), with one exception for timber under Art. 37(3)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 37, paragraph 3Click opens the article on EUR-Lex..

Which role you hold: operator, trader or downstream operator

Your duties depend on where you stand in the chain for each product, and one business can hold different roles for different products.

• Operator: places a listed product on the EU market or exports it, and is not a downstream operator (Art. 2(15)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 2, point 15Click opens the article on EUR-Lex.). Placing on the market is “the first making available” of the product on the EU market (Art. 2(16)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 2, point 16Click opens the article on EUR-Lex.). For goods made outside the EU the Commission’s guidance names, as a rule, the importer on the customs declaration for release for free circulation.
• Downstream operator: places on the market or exports listed products “made using relevant products, all of which are covered by a due diligence statement or by a simplified declaration” (Art. 2(15b)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 2, point 15bClick opens the article on EUR-Lex.). A chocolate maker that buys cocoa beans inside the EU and sells chocolate bars is the Commission’s own example.
• Trader: anyone else in the chain who makes listed products available on the market in the course of a commercial activity (Art. 2(17)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 2, point 17Click opens the article on EUR-Lex.). A shop that buys from an EU wholesaler and resells is a trader.

Selling from outside the EU. If the business placing the product on the market is based outside the EU, the first business based in the EU that makes the product available is treated as the operator as well (Art. 7Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 7Click opens the article on EUR-Lex.). For a product shipped straight to a consumer, the consumer is never the operator, even when the customs declaration names them as importer; the operator is the business actually supplying it, which the Commission’s guidance lists as the “manufacturer, seller, online retailer or fulfilment service provider”.

“Making available on the market” means “any supply of a relevant product for distribution, consumption or use on the Union market in the course of a commercial activity, whether in return for payment or free of charge” (Art. 2(18)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 2, point 18Click opens the article on EUR-Lex.). The Commission’s guidance reads that as requiring the product to be physically in the EU and released for free circulation; goods in customs warehousing, inward processing, temporary admission or transit are not placed on the market. Freight forwarders, shipping agents and customs representatives who do not own the goods are neither operators nor traders. Guidance is not law, but it is what the national authorities worked out with the Commission.

What each role must do

What goes in the due diligence statement

The statement goes into the EU information system the Commission runs (Art. 33(1)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 33, paragraph 1Click opens the article on EUR-Lex.), and carries: the operator’s name and address, with the EORI number when the goods cross the customs border; the customs code, description, trade name and quantity, and for wood the species’ full scientific name; the country of production and the geolocation of every plot of land the commodity came from; and a signed declaration that due diligence was done and “no or only a negligible risk” was found (Art. 4(2)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 4, paragraph 2Click opens the article on EUR-Lex., Annex II). Each statement gets a reference number, and that number goes to customs and to each downstream operator or trader you supply. The EUDR due diligence statement guide covers who files it, what goes in it and how to amend or withdraw it.

Geolocation means latitude and longitude “using at least six decimal digits”, and, for plots over four hectares producing anything other than cattle, a polygon around the plot (Art. 2(28)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 2, point 28Click opens the article on EUR-Lex.). For cattle it points to every establishment where the animals were kept (Art. 9(1)(d)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 9, paragraph 1, point (d)Click opens the article on EUR-Lex.). This is the information you need from your supplier before you can file.

Behind the statement sits the due diligence itself. You collect, and keep for five years, a description of the product, its quantity, the country of production, the geolocation and date of production, who supplied you and whom you supplied, and “adequately conclusive and verifiable information” that the product is deforestation-free and legally produced (Art. 9(1)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 9, paragraph 1Click opens the article on EUR-Lex.). You then run a risk assessment against the criteria in Art. 10(2)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 10, paragraph 2Click opens the article on EUR-Lex. and may sell only where it shows no or only a negligible risk (Art. 10(1)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 10, paragraph 1Click opens the article on EUR-Lex.); otherwise you mitigate first, for example by asking for more documents or commissioning independent surveys or audits (Art. 11(1)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 11, paragraph 1Click opens the article on EUR-Lex.). You keep the whole system under review at least once a year (Art. 12(2)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 12, paragraph 2Click opens the article on EUR-Lex.).

Where every commodity in the product was produced in countries the Commission has classified as low risk under Art. 29Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 29Click opens the article on EUR-Lex., and you have assessed your supply chain and found no risk of circumvention or of mixing with products from elsewhere, you may skip the risk assessment and mitigation, but you still collect the information and file the statement (Art. 13(1)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 13, paragraph 1Click opens the article on EUR-Lex.).

You may mandate an authorised representative based in the EU to submit the statement for you; you stay responsible for the product (Art. 6(1)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 6, paragraph 1Click opens the article on EUR-Lex.). An operator that is a natural person or a microenterprise may instead mandate the next business down the chain, if that business is neither, to file on its behalf (Art. 6(3)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 6, paragraph 3Click opens the article on EUR-Lex.).

When each date applies

The later date belongs to operators only (Art. 38(3)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 38, paragraph 3Click opens the article on EUR-Lex.); a trader or downstream operator of any size is bound from 30 December 2026. The EU Timber Regulation’s Annex covers fuel wood, wood in the rough, sawn wood, veneer, flooring, particle board, fibreboard, plywood, wooden frames, wooden packing cases and pallets, casks, builders’ joinery, pulp and paper of chapters 47 and 48, wooden furniture under 9403, and prefabricated wooden buildings. It does not cover wooden seats (9401), wooden tableware and kitchenware (4419), wooden ornaments and boxes (4420), tools and handles (4417) or other articles of wood (4421): for those, a micro or small operator has until 30 June 2027.

The dates have moved twice. The Regulation first applied its main articles from 30 December 2024 and gave micro and small operators until 30 June 2025. Regulation (EU) 2024/3234 moved them to 30 December 2025 and 30 June 2026. Regulation (EU) 2025/2650Regulation (EU) 2025/2650, amending the EU Deforestation RegulationThe whole regulationClick opens the law on the EU Publications Office. moved them to 30 December 2026 and 30 June 2027, and changed the cut-off for the later date from undertakings established by 31 December 2020 to those established by 31 December 2024 (Art. 38Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 38Click opens the article on EUR-Lex., as replaced by Art. 1(25)Regulation (EU) 2025/2650, amending the EU Deforestation RegulationThe whole regulationClick opens the law on the EU Publications Office. of Regulation (EU) 2025/2650Regulation (EU) 2025/2650, amending the EU Deforestation RegulationThe whole regulationClick opens the law on the EU Publications Office.). The Commission owed a simplification review by 30 April 2026 (Art. 34(1a)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 34, paragraph 1aClick opens the article on EUR-Lex.); it published it on 4 May 2026 as a report, guidance and a draft change to the product list, with no proposal to move the dates, and said its focus is “ensuring a successful entry into application of the law by 30 December 2026”.

The Commission’s guidance reads the dates per product: a product an operator placed on the market before its own date stays outside the Regulation, and so do products a trader or downstream operator later sells that are made entirely from it. A micro or small operator’s 30 June 2027 date therefore also shelters the traders further down its chain for the products it placed before that day.

Timber the old EU Timber Regulation covers, produced before 29 June 2023 and placed on the market from 30 December 2026, stays under that Regulation until 31 December 2029 and must meet EUDR’s Art. 3Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 3Click opens the article on EUR-Lex. from then (Art. 37(2)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 37, paragraph 2Click opens the article on EUR-Lex., Art. 37(3)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 37, paragraph 3Click opens the article on EUR-Lex.).

What changes for micro and small undertakings

EUDR takes its size classes from the Accounting Directive (Art. 2(30)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 2, point 30Click opens the article on EUR-Lex.). A micro-undertaking stays within at least two of three limits: €450,000 balance sheet total, €900,000 net turnover, 10 employees on average. A small undertaking stays within at least two of: €5,000,000 balance sheet total, €10,000,000 net turnover, 50 employees. A medium-sized one stays within at least two of €25,000,000, €50,000,000 and 250 employees (Art. 3(1)-(3)Directive 2013/34/EU, Accounting Directive (consolidated text of 18 March 2026)Article 3, paragraphs 1 to 3Click opens the article on EUR-Lex. of Directive 2013/34/EU). EUDR points to the first subparagraph of the small-undertaking rule, the one holding the €5,000,000 and €10,000,000 limits. The higher limits each EU country may set under the next subparagraph are not referred to.

What size changes:

• The date. An operator that is a natural person or a micro or small undertaking, established as such by 31 December 2024, starts on 30 June 2027 outside the EU Timber Regulation’s Annex (Art. 38(3)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 38, paragraph 3Click opens the article on EUR-Lex.).
• Registration. Only downstream operators and traders that are not SMEs register in the information system (Art. 5(2)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 5, paragraph 2Click opens the article on EUR-Lex.). An SME trader keeps its records and nothing more.
• Governance. Only operators that are not SMEs need a compliance officer at management level and an independent audit function (Art. 11(2)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 11, paragraph 2Click opens the article on EUR-Lex.), and only operators outside the SME and natural-person categories report publicly each year on their due diligence system (Art. 12(3)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 12, paragraph 3Click opens the article on EUR-Lex.).
• Filing through the next business. A natural person or microenterprise operator can have the next business down the chain file the statement for it (Art. 6(3)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 6, paragraph 3Click opens the article on EUR-Lex.).

A separate, lighter regime covers the “micro or small primary operator”: a natural person or a micro or small undertaking established in a country classified as low risk that places on the market products it “itself has grown, harvested, obtained from or raised” there (Art. 2(15a)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 2, point 15aClick opens the article on EUR-Lex.). It submits a one-time simplified declaration instead of a statement for each placing (Art. 4aRegulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 4aClick opens the article on EUR-Lex.). A business that buys goods to resell is not a primary operator.

What happens if you sell without it

Each EU country sets the penalties and designates the competent authority that enforces them (Art. 25(1)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 25, paragraph 1Click opens the article on EUR-Lex., Art. 14(1)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 14, paragraph 1Click opens the article on EUR-Lex.). The Regulation sets the floor. The penalties must include fines proportionate to the environmental damage and the value of the products, and for a legal person the maximum fine must be at least 4% of its total annual Union-wide turnover in the preceding financial year; confiscation of the products and of the revenue from them; exclusion for up to 12 months from public procurement and public funding; and, for a serious or repeated infringement, a temporary ban on placing, selling or exporting listed products (Art. 25(2)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 25, paragraph 2Click opens the article on EUR-Lex.). A different EU law, the Forced Labour Regulation, bans products made with forced labour from 14 December 2027, whatever the product, and has no statement to file.

Checks are set by quota. Each EU country must check every year at least 1% of the operators, and of the downstream operators and traders that are not SMEs, dealing in products from countries classified as low risk, 3% for standard risk, and 9% of the businesses and 9% of the quantity for high risk (Art. 16(8)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 16, paragraph 8Click opens the article on EUR-Lex., Art. 16(9)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 16, paragraph 9Click opens the article on EUR-Lex., Art. 16(10)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 16, paragraph 10Click opens the article on EUR-Lex.). At the border, the person lodging the customs declaration gives customs the statement’s reference number before the goods are released (Art. 26(4)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 26, paragraph 4Click opens the article on EUR-Lex.).

What you can set aside

What the law leaves open

• How “established as such by 31 December 2024” is measured. Art. 38(3)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 38, paragraph 3Click opens the article on EUR-Lex. gives the later date to operators that were micro or small undertakings “established as such by 31 December 2024”, and the Accounting Directive classes a business by its balance sheet dates. Neither text says which balance sheet date counts, or whether a business that has grown past the limits since then keeps the later date. Meanwhile, keep the accounts that show your size at the end of 2024; they are what an authority will look at.
• A sale shipped from outside the EU straight to a consumer. The Regulation’s own fallback, Art. 7Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 7Click opens the article on EUR-Lex., makes the first business based in the EU that makes the product available the operator, and in a direct sale there is none. The rule that fills the gap is the Commission’s guidance, not the Regulation: the operator is the business actually supplying the product, “manufacturer, seller, online retailer or fulfilment service provider”. Meanwhile, if you sell listed products from outside the EU to EU consumers, file as the operator, or mandate an authorised representative based in the EU to file for you under Art. 6(1)Regulation (EU) 2023/1115, EU Deforestation Regulation (consolidated text of 18 September 2026)Article 6, paragraph 1Click opens the article on EUR-Lex..