EUDR — EU Deforestation Regulation
Mandatory deforestation-free due diligence for seven commodities. Geolocation-level traceability required for all operators from December 2026.
Overview
The EU Deforestation Regulation (EUDR) — Regulation (EU) 2023/1115 — requires that products placed on the EU market or exported from the EU are deforestation-free. It mandates plot-level geolocation traceability and due diligence for seven commodities and their derivatives.
Legal basis
- Proposed: 17 November 2021
- Adopted: 31 May 2023
- Entered into force: 29 June 2023
- Original application date: 30 December 2024 (delayed twice)
- Current application date (large/medium operators): 30 December 2026
- Current application date (small/micro operators): 30 June 2027
Covered commodities
Seven primary commodities and their derived products:
- Cattle (including leather, beef)
- Cocoa (including chocolate products)
- Coffee
- Oil palm (including palm oil derivatives in cosmetics, food)
- Rubber (including tyres, industrial rubber)
- Soya (including animal feed, food products)
- Wood (including timber, furniture, pulp, paper)
Removed from scope (December 2025 revision): Printed products (books, newspapers).
Due diligence requirements
Step 1 — Information collection
- GPS polygon coordinates or point with radius of the production plot
- Country and sub-national production information
- Supplier/producer name and contact details
- Commodity description (CN code, quantity)
- Third-party certifications
Step 2 — Risk assessment
Assess risk of non-compliance using country/region benchmarking, forest presence, deforestation prevalence, indigenous land rights, and rule of law indicators.
Step 3 — Risk mitigation
Where risk is not negligible: independent audits, additional supplier information, capacity building measures.
Step 4 — Due diligence statement
Submit a due diligence statement to the EU information system before placing products on the market or exporting.
Simplified regime (December 2025 revision)
A simplified due diligence pathway for downstream operators — companies buying from other operators who have already submitted due diligence statements:
- Rely on upstream statements
- Submit simplified declaration instead of full due diligence
- Small/micro primary operators: simplified declaration form
Risk benchmarking
The Commission classifies countries/regions into three tiers:
- High risk: Full due diligence required, enhanced scrutiny
- Standard risk: Full due diligence required
- Low risk: Simplified due diligence
Penalties
Enforcement consequences under Art. 25 are among the most stringent of any EU sustainability regulation:
- Fines of at least 4% of the operator's or trader's total annual EU turnover in the preceding financial year
- Confiscation of the commodity and/or derived products
- Confiscation of revenues generated from the non-compliant transaction
- Temporary exclusion from public procurement (up to 12 months)
- Temporary prohibition from placing products on the EU market for serious or repeated infringements
- Public naming on the Commission's website — name, date, nature of infringement, and penalties imposed
Who is affected
All operators and traders placing covered commodities or derived products on the EU market, or exporting them from the EU:
- Importers of palm oil, soy, beef/cattle products, coffee, cocoa, rubber, and wood
- Importers of derived products: leather, chocolate, palm oil derivatives (cosmetics, food), rubber products (tyres, industrial rubber), paper, furniture, plywood, timber
- EU-based operators selling these commodities globally (export obligations apply)
- Downstream operators may rely on upstream due diligence statements (simplified pathway from December 2025 revision)
No minimum size threshold for large and medium operators from 30 December 2026. Small and micro operators follow from 30 June 2027 under a simplified regime.
Key articles
| Article | Subject | |---------|---------| | Art. 4 | Core prohibition — products must be deforestation-free and produced in accordance with source country laws | | Art. 9 | Due diligence obligations — three-step process (information, risk assessment, mitigation) | | Art. 25 | Penalties — minimum 4% of EU annual turnover, confiscation, public naming | | Art. 31 | Compliance checks — member state competent authorities | | Art. 32 | Enhanced compliance checks — high-risk country operators subject to 9% minimum check rate |
Key dates
| Date | Event | |------|-------| | 29 June 2023 | Entered into force | | 30 December 2024 | Original application date (delayed) | | December 2025 | Targeted revision: further delay + simplification | | 30 December 2026 | Application date — large/medium operators | | 30 June 2027 | Application date — small/micro operators |
Relevance to DPP
EUDR traceability data feeds into the broader DPP ecosystem:
- Geolocation provenance data supports ESPR DPP origin fields
- Due diligence statements create documented supply chain evidence
- Companies with EUDR systems have a head start on DPP supply chain data