The EU Deforestation Regulation (EUDR), Regulation (EU) 2023/1115, prohibits placing on, or exporting from, the EU market a defined set of commodities and products unless they are "deforestation-free," produced in line with the laws of the country of production, and covered by a due diligence statement. It replaces the earlier EU Timber Regulation and applies to seven commodities — cattle, cocoa, coffee, oil palm, rubber, soya and wood — plus a list of derived products in Annex I, such as leather, chocolate, furniture, tyres and printed paper.
The Regulation entered into force on 29 June 2023, but its substantive obligations have been postponed twice. Following Regulation (EU) 2025/2650 (published 23 December 2025), the main due diligence obligations apply from 30 December 2026 for large and medium-sized operators and traders, and from 30 June 2027 for micro and small enterprises and natural persons. Timelines have shifted before, so businesses should always confirm the current text on EUR-Lex.
What does the EUDR actually require?
The EUDR bans the placing on the EU market, making available, or export of in-scope commodities and products unless three conditions are all met:
- Deforestation-free — produced on land that was not subject to deforestation or, for wood, forest degradation, after 31 December 2020.
- Legally produced — produced in accordance with the relevant laws of the country of production (land use, environmental, labour, human rights, trade and customs rules, etc.).
- Covered by a due diligence statement — the operator has carried out due diligence and submitted a statement via the EU information system before the product is placed on the market or exported.
The obligation falls primarily on "operators" (the first to place a product on the EU market or export it). Traders that are not SMEs carry largely the same duties as operators.
Which commodities and products are in scope?
The Regulation covers seven commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood.
It also covers a defined list of derived products set out in Annex I and identified by Combined Nomenclature (customs) codes — for example beef and leather (cattle), chocolate and cocoa butter (cocoa), palm oil and certain derivatives (oil palm), tyres (rubber), soybean meal and oil (soya), and furniture, paper, pulp and charcoal (wood).
A product is in scope only if its specific code appears in Annex I. Checking the Annex I codes against a product's tariff classification is the standard way to confirm coverage.
What is "deforestation-free" and why does the 31 December 2020 cut-off matter?
"Deforestation-free" means the relevant commodities were produced on land that has not been subject to deforestation — and, for wood, that the forest has not been subject to degradation — after 31 December 2020.
The cut-off date is fixed and does not move with the application date. Land cleared of forest before 1 January 2021 can still supply EUDR commodities; land deforested on or after that date cannot, regardless of whether the clearing was legal locally.
The 2020 reference point aligns with international commitments to halt deforestation, including targets associated with the UN Sustainable Development Goals and the New York Declaration on Forests.
What due diligence, geolocation and traceability are needed?
Operators must run a three-step due diligence process and keep records for five years:
- Information collection — including a description of the product and quantity, country of production, supplier details, and the geolocation coordinates of all plots of land where the commodities were produced (with date or time range of production). Plots above 4 hectares generally require polygons rather than a single point.
- Risk assessment — evaluating the risk of non-compliance using factors such as country/region benchmarking, presence of forests, indigenous peoples' rights, corruption and supply-chain complexity.
- Risk mitigation — taking measures to reduce any non-negligible risk to negligible before proceeding.
A due diligence statement is then submitted through the EU information system, generating a reference number used downstream. The 2025 amendment streamlined how statements flow down the chain, including reduced obligations for newly defined "downstream operators" who handle products already covered by an upstream statement.
How does country benchmarking change the obligations?
The Commission classifies countries (or regions) into three risk tiers, set out in Commission Implementing Regulation (EU) 2025/1093 (published 22 May 2025):
- Low risk — the default for the large majority of countries, including all EU Member States and many major trading partners.
- Standard risk — countries not otherwise classified, including several large commodity-producing nations.
- High risk — a small number of countries (Belarus, Myanmar, North Korea and Russia), largely reflecting existing sanctions.
For commodities sourced from low-risk countries, operators may apply simplified due diligence (collecting information and confirming negligible risk, without the full risk assessment and mitigation steps). High-risk sourcing triggers enhanced scrutiny and a higher rate of competent-authority checks. The benchmarking list is reviewed and updated over time.
What are the penalties for non-compliance?
Member States set penalties, but Article 25 sets EU-wide minimum standards. Penalties must be effective, proportionate and dissuasive and include, at least:
- Fines proportionate to environmental damage and the value of the goods, with a maximum of at least 4% of the operator's or trader's total EU-wide annual turnover in the preceding financial year.
- Confiscation of the relevant products and of revenues gained from the transaction.
- Temporary exclusion (up to 12 months) from public procurement and public funding.
- For serious or repeated breaches, a temporary prohibition on placing, making available or exporting the relevant products, and exclusion from simplified due diligence.
Non-compliant products can also be ordered withdrawn or recalled from the market.
What is the current timeline after the delays?
The EUDR's application has been postponed twice. The current dates, following Regulation (EU) 2025/2650, are:
- 30 December 2026 — main obligations apply to large and medium-sized operators and traders.
- 30 June 2027 — main obligations apply to micro and small enterprises and natural persons.
The 31 December 2020 deforestation cut-off date is unchanged by these postponements. The 2025 amendment also introduced simplifications (reduced duties for downstream operators, a one-off simplified declaration for certain micro and small primary operators in low-risk countries). Because the timeline has moved before, the authoritative text on EUR-Lex should always be checked for the latest position.
Frequently asked questions
When does the EUDR start to apply?
The main obligations apply from 30 December 2026 for large and medium-sized operators and traders, and from 30 June 2027 for micro and small enterprises and natural persons, following the postponement in Regulation (EU) 2025/2650. The Regulation itself has been in force since 29 June 2023.
Which products does the EUDR cover?
Seven commodities — cattle, cocoa, coffee, oil palm, rubber, soya and wood — plus a list of derived products in Annex I (such as leather, chocolate, palm oil, tyres, soybean meal, furniture and paper), identified by customs (Combined Nomenclature) codes.
What does the 31 December 2020 cut-off date mean?
Commodities must be produced on land not subject to deforestation (or, for wood, forest degradation) after 31 December 2020. The date is fixed and does not move with the postponed application dates. Land cleared on or after 1 January 2021 cannot be used to supply EUDR products, even if the clearing was legal locally.
What is a due diligence statement?
A declaration submitted through the EU information system before placing a product on the market or exporting it, confirming the operator has carried out due diligence and found no more than negligible risk that the product is non-compliant. It references the geolocation of all plots where the commodities were produced and generates a reference number used by downstream operators and traders.
How does country risk benchmarking affect my obligations?
The Commission classifies countries as low, standard or high risk (first list in Implementing Regulation (EU) 2025/1093). Low-risk sourcing allows simplified due diligence, while standard- and high-risk sourcing requires full risk assessment and mitigation and attracts more competent-authority checks.
What happens if a company does not comply?
Member States must impose effective, proportionate and dissuasive penalties, including fines of at least 4% of EU-wide annual turnover, confiscation of products and revenues, exclusion from public procurement and funding for up to 12 months, and — for serious or repeated breaches — temporary trading bans and product withdrawals.