What is the EU Deforestation Regulation (EUDR)?

The EU Deforestation Regulation (EUDR) aims to stop products sold in the EU from driving deforestation and forest degradation. It replaced the EU Timber Regulation and covers seven commodities and many products made from them. Companies that place these products on the EU market, or export them, must show that they come from land that was not deforested after 31 December 2020 and were produced legally in the country of production.

What it covers

The regulation applies to seven relevant commodities:

• cattle
• cocoa
• coffee
• oil palm
• rubber
• soya
• wood

It also covers the relevant products listed in Annex I by customs code, such as beef, chocolate, palm oil, soya meal, tyres, furniture, paper and charcoal. A product not listed in Annex I is out of scope even if it contains one of the commodities.

Annex I has changed twice. Regulation (EU) 2025/2650 removed printed books and newspapers. Commission Delegated Regulation (EU) 2026/2102, published on 17 September 2026, removed cattle hides, skins and leather, conveyor belts and other articles of vulcanised rubber, and aircraft and motor vehicle seats. It added soluble coffee, frozen cattle tongues and certain palm oil derivatives, which are covered from 30 December 2027.

The three conditions

Under Article 3, relevant products can only be placed on the EU market or exported if they are:

1. deforestation-free: produced on land not deforested after 31 December 2020, and for wood, harvested without causing forest degradation after that date;
2. legal: produced in line with the relevant laws of the country of production;
3. covered by a due diligence statement or, for micro and small primary operators, a simplified declaration.

Due diligence and geolocation

Before placing products on the market, an operator must collect information, assess the risk that the products are not compliant, and reduce that risk to no more than negligible. The information includes the product, quantity, supplier, country of production and the geolocation of every plot of land where the commodity was produced (Article 9). Points with latitude and longitude are enough for small plots. For plots over four hectares, most commodities need a polygon of the plot's perimeter.

The operator then submits a due diligence statement in the EU Information System, part of the Commission's TRACES platform, and receives a reference number. Statements must be kept for five years.

The Commission classifies countries as low, standard or high risk, first adopted in May 2025. Products sourced only from low-risk countries qualify for simplified due diligence: the operator still collects the information but does not need to assess and mitigate risk.

Application dates and the 2024 to 2026 changes

The EUDR entered into force on 29 June 2023 and was due to apply from 30 December 2024. It has been changed since:

• Regulation (EU) 2024/3234 moved the start to 30 December 2025.
• Regulation (EU) 2025/2650, published on 23 December 2025, moved it to 30 December 2026 for medium and large companies and 30 June 2027 for micro and small companies established by 31 December 2024. It also created the downstream operator role: companies that make products from goods already covered by a statement no longer submit their own statements. Traders no longer do either. The first downstream operator or trader in the chain must collect and keep the reference numbers of the statements or simplified declarations covering its products. Micro and small primary operators in low-risk countries file a one-time simplified declaration instead.
• Delegated Regulation (EU) 2026/2102 adjusted the product scope, as described above.

On 4 May 2026, the Commission published its simplification review, COM(2026) 191, with updated guidance and FAQs. It concluded that it does not consider it appropriate to propose further amendments to the regulation, and is working toward application on 30 December 2026.

Fines must reach at least 4% of the company's total annual EU turnover at their maximum (Article 25(2)(a)), alongside confiscation of products and revenues and temporary exclusion from public procurement.

EUDR and product traceability

The EUDR is a traceability law at its core: the geolocation of a plot has to be linked through every processing step to the product that reaches the EU market. It does not use the Digital Product Passport, but both rely on the same building blocks: unique identifiers for products and batches, records of where and when each step happened, and supplier data collected in a structured form. Event standards such as EPCIS are one way to record that chain.

How to prepare

1. Check your products against Annex I by customs code, including the September 2026 changes.
2. Work out your role for each product: operator, downstream operator or trader, and your company size.
3. Collect geolocation data from suppliers for every plot, with polygons where the plot is over four hectares.
4. Keep each shipment traceable to its plots, so mixed batches do not break the chain.
5. Register in the EU Information System and plan how reference numbers will travel with your goods.
6. Keep records for five years.