EUDR — EU Deforestation Regulation
Mandatory deforestation-free due diligence for seven commodities. Geolocation-level traceability required from 30 December 2026 for large and medium operators, and from 30 June 2027 for most micro and small operators.
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
- Micro and small operators already covered by the EU Timber Regulation (EUTR): 30 December 2026 (European Commission)
- Postponing and simplifying act: Regulation (EU) 2025/2650
- Product-scope amendment: Delegated Regulation (EU) 2026/2102, in force since 18 September 2026
- Information System rules: Implementing Regulation (EU) 2024/3084, as amended by Implementing Regulation (EU) 2026/1565
Covered commodities
Seven primary commodities and their derived products:
- Cattle (including beef; cattle hides, skins and leather removed from 18 September 2026)
- Cocoa (including chocolate products)
- Coffee
- Oil palm (including palm oil derivatives in cosmetics, food)
- Rubber (including natural rubber and tyres; vulcanised rubber belting and other vulcanised rubber articles removed from 18 September 2026)
- Soya (including animal feed, food products)
- Wood (including timber, furniture, pulp, paper)
Removed from scope (December 2025 revision): Printed products (books, newspapers).
Annex I changes: Delegated Regulation (EU) 2026/2102
Commission Delegated Regulation (EU) 2026/2102 amends the list of relevant products in Annex I. It was adopted on 13 July 2026, published in the Official Journal on 17 September 2026 and entered into force on 18 September 2026.
Removed from 18 September 2026:
- Raw hides and skins of cattle (ex 4101), tanned or crust hides and skins of cattle (ex 4104) and leather of cattle (ex 4107)
- Conveyor or transmission belts or belting of vulcanised rubber (ex 4010)
- Other articles of vulcanised rubber other than hard rubber (ex 4016)
Narrowed from 18 September 2026:
- Soya beans: soya beans for sowing are excluded (the entry becomes 1201 90 00)
- Retreaded tyres: only new rubber tread remains in scope (ex 4012 90 30)
- Seats: aircraft seats (9401 10 00) and motor-vehicle seats (9401 20 00) are excluded
- Waste, used and second-hand products, samples, packing materials, marketing materials and items of correspondence are excluded
Added from 30 December 2027:
- Frozen cattle tongues (ex 0206 21 00)
- Soluble coffee: extracts, essences and concentrates of coffee (2101 11 00)
- Palm-oil derivatives and oleochemicals, including fatty alcohols and crude glycerol. The full list of codes is in the Annex to the delegated regulation.
The removals took legal effect on 18 September 2026. Because due diligence obligations start on 30 December 2026, the removed products leave scope before any obligation applies to them.
Simplification review: COM(2026) 191
The Commission's simplification review of 4 May 2026, COM(2026) 191, concluded that it "does not consider it appropriate to propose further amendments to the basic legal text", in order "to preserve legal certainty". The review relies instead on guidance and FAQs, IT changes and the Annex I delegated act that became Regulation 2026/2102. The application dates of 30 December 2026 and 30 June 2027 set by Regulation (EU) 2025/2650 are unchanged.
Proposed, not law: Commission proposal COM(2026) 661 of 10 September 2026 (procedure 2026/0261(CNS)) would exclude French Guiana from the EUDR's territorial scope (EUR-Lex).
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
Information System changes: Implementing Regulation (EU) 2026/1565
Implementing Regulation (EU) 2026/1565, in force since 17 July 2026, amends the Information System rules in Implementing Regulation (EU) 2024/3084 to reflect the December 2025 revision (EUR-Lex):
- Micro and small primary operators can submit and update a simplified declaration in the Information System
- Users can group due diligence statements or simplified declarations they submitted earlier into a new one, and then quote its single reference number
- From 15 October 2026, due diligence statements of operators established outside the EU are attributed to the competent authorities of the Member State linked to the operator's identifier in the Information System
- By 30 December 2026, the Commission must publish on a public website information on the Information System's availability and the contingency measures that apply when it is unavailable for more than 60 minutes, including contingency reference numbers (new Article 15a)
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 proportionate to the environmental damage and the value of the products concerned. For a legal person, the maximum fine must be at least 4% of its total annual Union-wide turnover in the preceding financial year, so 4% is a floor for the maximum, not a cap (Art. 25(2)(a)) (consolidated text: EUR-Lex)
- 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: chocolate, palm oil derivatives (cosmetics, food), natural rubber and tyres, paper, furniture, plywood, timber. Cattle leather, vulcanised rubber belting and other vulcanised rubber articles are out of scope from 18 September 2026 (Delegated Regulation (EU) 2026/2102)
- From 30 December 2027: importers of soluble coffee, frozen cattle tongues and the palm-oil derivatives added by Delegated Regulation (EU) 2026/2102
- 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, except those already covered by the EU Timber Regulation, which must comply from 30 December 2026.
Key articles
| Article | Subject |
|---|---|
| Art. 3 | Prohibition: products must be deforestation-free, produced in accordance with the relevant legislation of the country of production, and covered by a due diligence statement or simplified declaration |
| Art. 8 | Due diligence: information collection (Art. 9), risk assessment (Art. 10) and risk mitigation (Art. 11) |
| Art. 16 | Checks by Member State competent authorities, using a risk-based approach |
| Art. 16(8) to (10) | Minimum annual check rates: 9% of operators and 9% of product quantity for high-risk countries, 3% for standard risk, 1% for low risk |
| Art. 25 | Penalties: for legal persons, a maximum fine of at least 4% of total annual Union-wide turnover; confiscation; publication of final judgments |
Key dates
| Date | Event |
|---|---|
| 29 June 2023 | Entered into force |
| 30 December 2024 | Original application date (delayed) |
| December 2025 | Targeted revision: further delay + simplification (Regulation (EU) 2025/2650) |
| 4 May 2026 | Simplification review COM(2026) 191: no further amendments to the basic text |
| 17 July 2026 | Implementing Regulation (EU) 2026/1565 in force: simplified declarations and grouping in the Information System |
| 18 September 2026 | Delegated Regulation (EU) 2026/2102 in force: leather, rubber belting and other vulcanised rubber articles removed from Annex I |
| 15 October 2026 | New attribution rules for due diligence statements of operators established outside the EU |
| 30 December 2026 | Application date: large and medium operators, and micro and small operators already covered by the EU Timber Regulation |
| 30 December 2026 | Deadline for the Commission to publish Information System availability and contingency information |
| 30 June 2027 | Application date: other micro and small operators |
| 30 December 2027 | Annex I additions apply: soluble coffee, frozen cattle tongues, palm-oil derivatives |
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
Source
- Regulation (EU) 2023/1115 — EUR-Lex
- Regulation (EU) 2025/2650 — EUR-Lex
- Delegated Regulation (EU) 2026/2102 — EUR-Lex
- Implementing Regulation (EU) 2026/1565 (Information System): EUR-Lex
- European Commission: Regulation on deforestation-free products, application dates
- Simplification review COM(2026) 191 — EUR-Lex
- Proposal COM(2026) 661 (French Guiana, proposed): EUR-Lex
- Council December 2025 revision