The plain-English explainer
What is the EU Deforestation Regulation (EUDR)?
The EUDR is an EU law that stops products linked to recent deforestation from being sold in, or exported from, the EU. It covers seven commodities and many products made from them, and it asks companies to prove their goods are both deforestation-free and legally produced. Regulation (EU) 2023/1115 sets all of this out; this page explains it without the legalese.
TL;DR
- What: the EU Deforestation Regulation, Regulation (EU) 2023/1115. It replaced the older EU Timber Regulation.
- Who: EU operators, traders and downstream operators, plus, in practice, their non-EU suppliers.
- When: 30 December 2026 for large and medium companies; 30 June 2027 for micro and small ones.
- The test: in-scope products must be deforestation-free (no clearing after 31 December 2020) and legally produced.
- What is covered: seven commodities, cattle, cocoa, coffee, oil palm, rubber, soya and wood, plus products derived from them.
Confirmed deadlines
30 December 2026
Large and medium operators and traders must comply.
30 June 2027
Micro and small enterprises must comply, if established as such by 31 December 2024.
Confirmed in law after the second delay, December 2025. Council, targeted revision. See the full deadline tracker.
What the EUDR is, and what it is for
The EU Deforestation Regulation, EUDR for short, is Regulation (EU) 2023/1115, adopted on 31 May 2023. Its goal is to curb deforestation and forest degradation driven by EU consumption, by making sure that key commodities and the products made from them are deforestation-free and produced legally in their country of origin. It is a flagship measure of the European Green Deal. European Commission
The EUDR replaced the older EU Timber Regulation (EUTR). The EUTR only covered timber and only banned illegally harvested wood. The EUDR is broader on both counts: it adds six more commodities and layers a new deforestation-free test on top of the legality test. The key reference point is the cut-off date of 31 December 2020: goods linked to land that was deforested after that date are not allowed on the EU market. Art. 2(13)
Who must comply
The duty falls on EU-side companies, in three roles.
Operator
First places an in-scope product on the EU market, or exports it. Carries the heaviest load: full due diligence and filing the Due Diligence Statement.
Trader
Further down the chain, making the product available. Mostly collects and passes on reference numbers rather than filing fresh statements.
Downstream operator
A category added in December 2025 for companies working with inputs already covered by someone else's statement. Trader-like, lighter duties; files no new statement.
Smaller companies (SMEs) get lighter obligations and a later start date. And while non-EU suppliers are not directly regulated, they are pulled in contractually: the EU operator has to collect geolocation and legality evidence from upstream, so producers worldwide end up supplying plot coordinates and documents to keep their EU buyers. European Commission
Not sure which role is yours? Use the scope checker for a plain-English steer.
The seven commodities, plus their derived products
The EUDR covers seven raw commodities. Crucially it also covers a long list of products derived from them, set out in Annex I by CN/HS customs code. Art. 1 and Annex I
Derived products are in scope too
Rule of thumb
Proposed, not yet law
The dual test: deforestation-free AND legal
An in-scope product can only be placed on the market, made available or exported if it passes two tests and is covered by a Due Diligence Statement. Art. 3
- Deforestation-free means produced on land not deforested after 31 December 2020. For wood, also harvested without causing forest degradation after that date.
- Legally produced means made in line with the laws of the country of production, covering land-use rights, environmental and forest rules, third parties' rights, labour and human rights, Free Prior and Informed Consent, and tax, anti-corruption, trade and customs rules.
Both have to be true. Legal but linked to recent deforestation is not enough, and vice versa.
Due diligence in three steps
To meet the test, operators run a due-diligence process in three steps.
1. Collect information
Gather and keep, for five years, the product description and quantity, country of production, the geolocation of every plot, supplier and buyer details, plus evidence the product is deforestation-free and legal. Art. 9
2. Assess the risk
Weigh the chance of non-compliance using factors like the country's risk tier, the presence of forests and indigenous peoples, supply-chain complexity and the risk of mixing with unknown-origin material. Art. 10
3. Mitigate the risk
If risk is more than negligible, do something about it, such as gathering more information or commissioning audits, until it is negligible before the product goes on sale. Art. 11
The DDS, the Information System and your reference numbers
Once due diligence is done, the operator files a Due Diligence Statement (DDS) electronically through the EU Information System, built on the EU's TRACES platform, before placing the product on the market or exporting it.
The statement includes the operator's identity, the product's HS code, description and quantity, the country of production, the geolocation coordinates or polygons of the relevant plots, and a declaration that risk is negligible. Art. 33 and Annex II
On submission the system issues two numbers.
Reference number
Passed down the supply chain so the next company can show their goods are already covered by a statement.
Verification number
Issued alongside the reference number when the DDS is submitted to the EU Information System. EU Information System
TRACES access is in flux
Country benchmarking: low, standard, high risk
The EU sorts countries (or regions) into three risk tiers, which decide how much due diligence and how many checks apply. Country benchmarking was first set by Implementing Regulation (EU) 2025/1093 of 22 May 2025. Art. 29
- Low risk: simplified due diligence. You still collect the information and confirm negligible risk, but skip the full risk assessment and mitigation. Around 140 countries, including all EU states, the UK, US, China and Japan.
- Standard risk: full due diligence. The default tier, including Brazil, Indonesia and Malaysia.
- High risk: full due diligence plus enhanced scrutiny. Just four countries: Belarus, Myanmar, North Korea and Russia.
Want to look up a specific country? Use the country-risk lookup.
The list will be reviewed in 2026
Penalties and checks
Penalties must be effective, proportionate and dissuasive. For a company, the maximum fine must be at least 4% of total EU-wide annual turnover, and can rise for repeat breaches. Authorities can also confiscate products or the revenue from them, exclude a company from public procurement and funding for up to 12 months, and impose temporary market bans. Art. 25
Enforcement is by each country's competent authority, with minimum annual check rates set by risk tier: at least 9% of operators in high-risk, 3% in standard-risk and 1% in low-risk. Art. 16
Recent changes
The EUDR is a moving target. The most important recent changes:
- Two delays. A first delay in December 2024, then a second via Regulation (EU) 2025/2650, published 23 December 2025, set the current dates of 30 December 2026 and 30 June 2027. Council press release
- The December 2025 simplifications. The new downstream-operator category, lighter rules for passing reference numbers down the chain, a one-time simplified declaration for micro and small primary producers in low-risk countries (where a postal address can replace geolocation in some cases), and annual rather than per-shipment statements where allowed.
- The 4 May 2026 simplification review. Updated guidance and FAQ, plus the proposed Annex I scope change (see below). Guidance document
Proposed Annex I changes, not yet law
By the numbers
The EUDR in a few figures
Commodities in scope: cattle, cocoa, coffee, oil palm, rubber, soya, wood.
The cut-off date. Goods linked to land deforested after this are not allowed.
Countries currently high-risk: Belarus, Myanmar, North Korea, Russia.
Minimum maximum fine, as a share of EU-wide annual turnover.
Official checks run at 9% of operators in high-risk countries, 3% in standard-risk and 1% in low-risk. Reg. (EU) 2023/1115
FAQ
People also ask
- What is the EUDR?
- The EUDR is the EU Deforestation Regulation, Regulation (EU) 2023/1115. It bans products linked to deforestation after 31 December 2020 from being sold in, or exported from, the EU, and requires companies to prove their products are deforestation-free and legally produced. It covers seven commodities (cattle, cocoa, coffee, oil palm, rubber, soya and wood) and many products made from them.
- When does the EUDR apply?
- After the second delay, confirmed in December 2025, large and medium operators and traders must comply from 30 December 2026, and micro and small enterprises from 30 June 2027. The six-month grace for smaller firms applies only to those already established as micro or small by 31 December 2024.
- What products are covered by the EUDR?
- Seven commodities (cattle, cocoa, coffee, oil palm, rubber, soya and wood) plus a long list of derived products in Annex I, such as leather, chocolate, coffee, furniture, paper, palm oil and tyres. Each product is listed by its CN/HS customs code, so you confirm scope by matching your product code against Annex I.
- Who has to comply with the EUDR?
- EU-side operators (companies that first place an in-scope product on the EU market or export it), traders and the new downstream-operator category. Non-EU suppliers are not directly regulated, but they are pulled in contractually because EU buyers must collect geolocation and legality data from them.
- What is a DDS?
- A DDS is a Due Diligence Statement: the short electronic declaration you file in the EU Information System before placing a product on the market or exporting it. It confirms you did due diligence and found no, or only negligible, risk. On submission you receive a reference number and a verification number.
- What is the difference between an operator and a trader?
- An operator first places an in-scope product on the EU market or exports it, and carries the full due-diligence and DDS obligations. A trader is further down the chain and mostly collects and passes on reference numbers rather than filing fresh statements. A downstream operator works with inputs already covered by someone else's DDS and has trader-like, lighter duties.
- What are the penalties under the EUDR?
- Fines of at least 4% of a company's EU-wide annual turnover for the most serious breaches, plus confiscation of products or revenue, exclusion from public procurement and funding for up to 12 months, and temporary market bans. Authorities must check at least 9% of operators in high-risk countries, 3% in standard-risk and 1% in low-risk.
- Is the EUDR delayed?
- It was postponed twice. The current, confirmed application dates are 30 December 2026 for large and medium companies and 30 June 2027 for micro and small ones. No further delay is law as of June 2026, and the Commission has said the core regulation will not be reopened, though political pressure continues.
- Which countries are high-risk under the EUDR?
- Four countries are currently classed high-risk: Belarus, Myanmar, North Korea and Russia. Around 140 countries (including all EU states, the UK, US, China and Japan) are low-risk, and the rest, including Brazil, Indonesia and Malaysia, are standard-risk. A first review of the list is scheduled for 2026.
- Is packaging covered by the EUDR?
- Packaging is in scope only when it is itself a relevant product, for example wooden or paper packaging that falls under an Annex I code. Packaging used purely to support, protect or carry another product is generally not the thing being regulated. Always confirm against the specific CN/HS codes in Annex I.
This is guidance, not legal advice
Sources
- [1]Regulation (EU) 2023/1115, consolidated text (EUR-Lex)retrieved 4 Jun 2026
- [2]European Commission: Regulation on deforestation-free productsretrieved 4 Jun 2026
- [3]European Commission Green Forum: EUDR implementationretrieved 4 Jun 2026
- [4]EU Information System (TRACES) for the EUDRretrieved 4 Jun 2026
- [5]EUDR guidance document (European Commission)retrieved 4 Jun 2026
- [6]FAQ on EUDR implementation (European Commission)retrieved 4 Jun 2026
- [7]SME factsheet (European Commission Green Forum)retrieved 4 Jun 2026
- [8]Council of the EU: targeted revision (second delay and simplification)retrieved 4 Jun 2026
- [9]EUR-Lex summary of the EUDRretrieved 4 Jun 2026
The EUDR Brief
Subscribe to The EUDR Brief
We watch Brussels so you don't. Plain-English EUDR updates, free.
No spam. Unsubscribe anytime.