EUDR Compliance: Requirements and the 2026 Deadline

The EU Deforestation Regulation (EUDR), formally Regulation (EU) 2023/1115, prohibits placing on the EU market, making available, or exporting seven commodities and their derived products unless they are deforestation-free, produced legally in the country of origin, and covered by a due diligence statement. After two postponements, large and medium-sized companies must comply from 30 December 2026, and micro and small enterprises from 30 June 2027.

If your portfolio includes anything made from wood, rubber, palm oil, soy, cocoa, coffee, or cattle-derived materials, EUDR applies to you even if you have never thought of your company as being in the "forest commodities" business. Furniture, toys with wooden parts, tyres, leather goods, chocolate, and paper packaging placed on the market as a product in its own right can all fall in scope. With the December 2026 deadline now firm and the European Commission's simplification package published in May 2026, the preparation window is the second half of 2026. This guide covers what the regulation requires, who must do what, and how to get ready.

What is the EU Deforestation Regulation (EUDR)?

The EU Deforestation Regulation is an EU regulation that requires companies to prove that specific commodities and derived products they place on the EU market or export from it did not come from land deforested or degraded after 31 December 2020. It was adopted on 31 May 2023, entered into force on 29 June 2023, and replaces the EU Timber Regulation (EU) No 995/2010.

Unlike a product safety regulation such as the General Product Safety Regulation (GPSR), the EUDR regulates the origin of raw materials rather than the characteristics of the finished product. Compliance is demonstrated through supply chain traceability: knowing exactly which plots of land your materials came from, and being able to show it. As part of the EU Green Deal, it sits alongside a wave of sustainability legislation that is moving compliance obligations upstream into the supply chain.

Two amendments have reshaped the timeline and obligations since adoption. Regulation (EU) 2024/3234 postponed the original application date by one year, and Regulation (EU) 2025/2650, adopted on 19 December 2025, postponed it again while simplifying who must submit due diligence statements. The core obligations, the commodity scope, and the penalty regime remain intact.

The EUDR covers seven commodities: cattle, cocoa, coffee, oil palm, rubber, soya, and wood. It also covers products derived from them, listed in Annex I of the regulation by customs (HS) code. Derived products include leather, chocolate, tyres, furniture, charcoal, palm-oil derivatives, and paper products, among many others.

Two scope notes matter for product companies. First, scope is determined by the Annex I HS code list, not by intuition: a product either falls under a listed code or it does not. Second, Regulation (EU) 2025/2650 removed printed products such as books from the scope. A draft delegated act published with the Commission's May 2026 simplification package proposes further targeted revisions to Annex I: 17 product codes added (including instant coffee and certain palm-oil derivatives), three removed (including retreaded tyres and cattle leather), and one clarified. The public feedback period closed on 1 June 2026 and the act is pending formal adoption, so the final list may still change.

Note that paper and cardboard packaging placed on the market as a product in its own right can fall in scope, on top of the obligations it already carries under Extended Producer Responsibility schemes. The same physical item increasingly triggers more than one EU compliance regime.

Date	Milestone	Status
29 June 2023	Regulation (EU) 2023/1115 enters into force	Confirmed
30 December 2024	Original application date	Superseded by Regulation (EU) 2024/3234
30 December 2025	First postponed application date	Superseded by Regulation (EU) 2025/2650
22 May 2025	Commission adopts country benchmarking classification	Confirmed
4 May 2026	Commission publishes simplification review (COM(2026) 191 final), updated guidance, and draft delegated act	Confirmed
30 December 2026	Application for large and medium-sized operators and traders	Confirmed
30 June 2027	Application for micro and small enterprises and natural persons	Confirmed

According to the European Commission, the May 2026 simplification measures are expected to reduce annual compliance costs by roughly 75% compared with the original 2023 estimates. The EU Information System, a dedicated tool on the TRACES platform, is operational: a production server where submitted due diligence statements have legal value, and an acceptance server for training, familiarisation, and testing. The system operates under Commission Implementing Regulation (EU) 2024/3084, with an update pending to reflect the amended EUDR provisions.

The EUDR distinguishes between two roles. An operator is any company that places a relevant product on the EU market for the first time or exports it from the EU. A trader is any company in the supply chain, other than the operator, that makes the product available on the market. Both roles carry obligations, but the weight sits with operators.

Regulation (EU) 2025/2650 simplified the chain significantly: only the business that first places a relevant product on the EU market is responsible for submitting the due diligence statement. Companies further down the chain no longer submit new statements for the same product; they rely on the reference numbers of statements already submitted upstream. Micro and small primary operators benefit from a one-off simplified declaration instead of repeated submissions.

For non-EU brands, the practical consequence is that their EU importer typically becomes the operator and carries the due diligence obligation. For EU retailers with own-brand products sourced outside the EU, the retailer itself is usually the operator. That makes EUDR readiness a direct function of how well you can extract verifiable origin data from your suppliers.

This is where most companies feel the pain first: not in understanding the regulation, but in collecting the evidence. Chasing suppliers for documents at scale is already the hidden cost of compliance work. It is the same challenge that led companies like Flying Tiger Copenhagen, which launches around 500 new products per month across 44 countries, to run supplier document collection as a structured workflow in Complir rather than an email thread.

Article 3 of the EUDR sets three cumulative conditions. Relevant products may only be placed on the EU market or exported if they are:

1. Deforestation-free, meaning produced on land that was not subject to deforestation or forest degradation after 31 December 2020.
2. Produced in accordance with the relevant legislation of the country of production, covering areas such as land use rights, environmental protection, labour rights, and tax and anti-corruption rules.
3. Covered by a due diligence statement (DDS) submitted through the EU Information System before the product is placed on the market or exported.

Meeting these conditions requires a due diligence system with three steps: collecting information (Article 9), assessing risk (Article 10), and mitigating risk where it is more than negligible (Article 11). The Commission's May 2026 package added supporting tools for this exercise, including repositories of producing-country legislation for legality assessments and a framework for recognising certification schemes as inputs to risk assessment. Certification can inform your risk assessment, but it does not replace your own due diligence.

What must a due diligence statement include?

A due diligence statement must include the operator's identity and EORI number where applicable, a description of the product with its HS code and quantity, the country of production, the geolocation of all plots of land where the relevant commodities were produced, and a declaration that due diligence was carried out and no or only negligible risk was found.

Geolocation is the requirement that surprises most teams. Article 9(1)(d) of the EUDR requires geolocation coordinates for every plot of land where the relevant commodities a product contains were produced. The regulation's own definition of geolocation in Article 2(28) sets the precision: latitude and longitude coordinates using at least six decimal digits, with polygons required for plots larger than four hectares. The Information System accepts coordinates individually, drawn on a map, or in bulk in the GeoJSON standard format. For cattle, geolocation covers the establishments where the animals were kept.

For a quality or regulatory team, this means your supplier data requests need to go beyond certificates and test reports. You need plot-level coordinates flowing from the farm or forest through every tier of your supply chain to your product record.

What is EUDR country benchmarking?

Country benchmarking is the EUDR's system for classifying every country as low, standard, or high risk for deforestation, which determines how much due diligence effort is required. The European Commission adopted the first classification on 22 May 2025 through Commission Implementing Regulation (EU) 2025/1093. Belarus, Myanmar, North Korea, and Russia were classified as high risk. Around 50 countries, including major producers such as Brazil, Indonesia, and Malaysia, were classified as standard risk, and roughly 140 countries, including all EU Member States, the UK, the US, and China, as low risk.

The European Parliament adopted a resolution objecting to the classification methodology in July 2025, but the objection is not binding for an implementing act: Implementing Regulation (EU) 2025/1093 remains in force and the classifications remain valid. The Commission has indicated it will review the benchmarking, so sourcing teams should treat country risk categories as reviewable rather than permanent.

Sourcing from low-risk countries qualifies for simplified due diligence under Article 13: you must still collect the required information, including geolocation, but you are not obliged to run the full risk assessment and mitigation steps. Standard-risk and high-risk sourcing requires the full exercise, with products from high-risk countries subject to enhanced checks by authorities.

Member State authorities enforce the EUDR, and Article 25 sets the penalty framework. Fines must be proportionate to the environmental damage and the value of the products concerned, with a maximum of at least 4% of the operator's or trader's annual EU-wide turnover. Authorities can also confiscate the products and the revenues gained from them, and non-compliant companies can face temporary exclusion from public procurement and, for serious infringements, temporary prohibition from placing relevant products on the market.

Enforcement begins with the application dates: 30 December 2026 for large and medium companies, 30 June 2027 for micro and small enterprises. Checks are risk-based, with authorities required to inspect a higher share of operators sourcing from high-risk countries.

Does the EUDR apply to products already on the market?

Products placed on the market before the relevant application date are generally not subject to the due diligence obligation, with specific transitional rules for timber products previously covered by the EU Timber Regulation. The decisive moment is when a product is first placed on the EU market, so goods entering your warehouse and the market after 30 December 2026 need a due diligence statement even if they were ordered earlier. Verify the transitional provisions for your specific situation, as the rules differ by commodity history.

The EUDR is in force today and applies to large and medium companies from 30 December 2026. The seven-commodity scope reaches deep into ordinary consumer product portfolios: furniture, toys, tyres, leather, chocolate, coffee, and paper packaging are all candidates. Compliance stands on three legs: deforestation-free origin after the 31 December 2020 cut-off, legal production, and a due diligence statement with plot-level geolocation. The December 2025 amendment reduced the burden by making only the first placer on the market responsible for the DDS, and the May 2026 simplification package added guidance, legality repositories, and certification recognition. Penalties reach at least 4% of EU turnover, so treating this as a procurement-only topic is a risk in itself.

If your team is already stretched chasing supplier documentation for declarations of conformity and test reports, EUDR adds a new document type to the same broken process. Complir runs supplier document retrieval as a structured workflow: suppliers see exactly what is needed and in what format, incoming documents are classified automatically, and gaps are visible per product. See how Complir automates supplier document collection and regulatory monitoring.

Sources & References

• Regulation (EU) 2023/1115 on deforestation-free products: EUR-Lex
• Regulation (EU) 2025/2650 amending Regulation (EU) 2023/1115 as regards certain obligations of operators and traders: EUR-Lex
• Commission Implementing Regulation (EU) 2025/1093 on country benchmarking: EUR-Lex
• Regulation on Deforestation-free Products: European Commission, DG Environment
• The Information System of the Deforestation Regulation: European Commission Green Forum
• Implementing the EU Deforestation Regulation: European Commission Green Forum
• Commission simplification review of the EUDR, COM(2026) 191 final, 4 May 2026: European Commission press release
• Delay until December 2026 and other developments in the implementation of the EUDR: Access2Markets, European Commission
• Deforestation law: Parliament adopts changes to postpone and simplify measures: European Parliament press release, 11 December 2025

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This article is for informational purposes only and does not constitute legal advice. Regulatory requirements may vary by product category, market, and specific circumstances. Consult with a qualified legal professional for compliance guidance specific to your situation.