What do you need to know about the EUDR?

The seven relevant commodities are cattle, cocoa, coffee, oil palm, rubber, soya and wood (Article 2(1)). The Regulation was published in OJ L 150 of 9 June 2023 (p. 206), entered into force on 29 June 2023 and is amended by Regulations (EU) 2024/3234 and 2025/2650 and Delegated Regulation (EU) 2026/2102.

The rules below cover the dates, the legal text, scope, commodities, roles, compliance, country benchmarking and enforcement. Four roles carry different duties. Only operators exercise due diligence and file a due diligence statement in the EUDR Information System; micro or small primary operators file a one-time simplified declaration, and downstream operators and traders keep supplier and customer information (Article 5). National competent authorities check a minimum share of companies every year, set by the risk class of the country of production.

Table 1. The EUDR at a glance

What Is the EUDR?

The EUDR is an EU regulation that lets relevant products reach or leave the Union market only if they are deforestation-free, legally produced and covered by a due diligence statement or simplified declaration (Article 3). The three conditions are cumulative (Guidance C/2026/3896, section 6; FAQ Version 5 (April 2026), 1.29):

1. Deforestation-free (Article 3(a)): no deforestation after the cut-off date of 31 December 2020; for wood, also no forest degradation (Article 2(13)).
2. Legal (Article 3(b)): produced in accordance with the relevant legislation of the country of production.
3. Covered (Article 3(c)): covered by a due diligence statement or a simplified declaration, as point (c) reads since Regulation (EU) 2025/2650.

A relevant product is a product listed in Annex I that contains, has been fed with or has been made using relevant commodities (Article 2(2)). The EUDR also repeals the EU Timber Regulation, Regulation (EU) No 995/2010, with effect from 30 December 2026 (Article 37).

What Does EUDR Stand For?

EUDR stands for EU Deforestation Regulation, the common name of Regulation (EU) 2023/1115 of 31 May 2023. Its full title is "Regulation (EU) 2023/1115 of the European Parliament and of the Council of 31 May 2023 on the making available on the Union market and the export from the Union of certain commodities and products associated with deforestation and forest degradation and repealing Regulation (EU) No 995/2010". The Commission calls it the "Regulation on deforestation-free products"; neither short name is an official title. The Regulation was adopted under Article 192(1) TFEU in the ordinary legislative procedure, signed on 31 May 2023 and published on 9 June 2023.

Is the EUDR Mandatory?

Yes: the EUDR is binding in its entirety and directly applicable in all Member States; national law designates the competent authorities and lays down penalties, and nothing is transposed. Its obligations apply to every company in scope from 30 December 2026 (Article 38(2)), whether or not a national law exists by then.

National law has two tasks under the Regulation: designating one or more competent authorities (Article 14(1)) and laying down the penalties for infringements (Article 25). Calling such a law a transposition is wrong, because a regulation is not transposed.

When Does the EUDR Apply? Timeline, Delay and Simplification

The EUDR has been in force since 29 June 2023, and its main obligations apply from 30 December 2026 (Article 38(2) as replaced by Regulation (EU) 2025/2650). That date covers Articles 3 to 13, 16 to 24, 26, 31 and 32; Articles 1, 2, 14, 15, 25, 27 to 30 and 33 to 38 have applied since entry into force. Because Articles 14, 25, 29 and 33 already apply, Member States designate authorities and lay down penalties, the Commission classifies countries and the EUDR Information System operates before the obligations start. Operators that are natural persons or micro or small undertakings established as such by 31 December 2024 apply the obligations from 30 June 2027 (Article 38(3)); products in the Annex to Regulation (EU) No 995/2010 from 30 December 2026. The 18 Annex I lines added by Delegated Regulation (EU) 2026/2102 carry obligations from 30 December 2027. The deforestation cut-off date of 31 December 2020 (Article 2(13)) has never been amended.

The application date has moved twice. Regulation (EU) 2024/3234 postponed it from 30 December 2024 to 30 December 2025, and Regulation (EU) 2025/2650 postponed it to 30 December 2026, with a later date for the deferred operators. As of 24 October 2026, no proposal to postpone the EUDR again exists. The six-month grace period proposed in COM(2025) 652 of 21 October 2025 was never adopted. The Commission's simplification review, COM(2026) 191 of 4 May 2026 under Article 34(1a), proposes no further amendment of the basic text, and a general review follows by 30 June 2030 (Article 34(2)).

Table 2. EUDR dates and status

What Is in Regulation (EU) 2023/1115? Articles, Annex I, Guidance and FAQ

Regulation (EU) 2023/1115 has 39 articles in 9 chapters and three annexes, and its current text is the consolidated version of 18 September 2026 (02023R1115-20260918). The 39 articles are Articles 1 to 38 plus Article 4a; Article 2 defines terms in 42 points, and 86 recitals precede the articles. Annex I lists the relevant products by CN code, Annex II the content of the due diligence statement and Annex III, added on 26 December 2025, the content of the simplified declaration.

Three acts amend the text. Regulation (EU) 2024/3234 entered into force on 26 December 2024 and Regulation (EU) 2025/2650 (OJ L, 2025/2650, 23.12.2025) on 26 December 2025. Commission Delegated Regulation (EU) 2026/2102, adopted on 13 July 2026 and published on 17 September 2026, entered into force on 18 September 2026. The consolidated text on EUR-Lex integrates all three.

The Commission explains the rules in Commission Notice C/2026/3896 (the third edition of its Guidance, OJ C of 20 July 2026) and in FAQ Version 5 (April 2026). Both are non-binding (Article 15(5)): where a rule rests only on them, it is the Commission's view. The official website of the EUDR is the Commission's Regulation on deforestation-free products page. The CN codes of every covered product sit in Annex I, not in the articles.

Table 3. The legal text and official instruments

Which Products, Companies and Transactions Fall Within the EUDR Scope?

The EUDR covers every Annex I product that a company places on the Union market, makes available on it or exports in the course of a commercial activity (Articles 1 and 2(16), (18), (19)). Placing on the market is the first making available of a product on the Union market (Article 2(16)). Making available covers any supply, whether in return for payment or free of charge (Article 2(18)), and export is defined in Article 2(37).

Three limits frame the scope. Annex I has no de minimis threshold, so small quantities are covered (FAQ 2.3). Products produced before 29 June 2023 fall outside the Regulation (Article 1(2)), except timber under the transition of Article 37(3). Company size removes no obligation: since Regulation (EU) 2025/2650 deleted the derogation of Article 4(8), SME operators carry full due diligence and file their own due diligence statement. A small number of carve-outs, such as samples and test products, are listed in the notes to Annex I.

Table 4. Scope in detail

Which Commodities Does the EUDR Cover? Cattle, Cocoa, Coffee, Oil Palm, Rubber, Soya and Wood

The EUDR covers seven relevant commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood (Article 2(1)), and the 89 Annex I entries made from them. Notes (1) to (4) of Annex I, inserted by Delegated Regulation (EU) 2026/2102, narrow four of them: cattle means animals of the genus Bos, oil palm means Elaeis spp., rubber means Hevea brasiliensis and not synthetic rubber, and wood excludes bamboo and rattan. A product made from a commodity but not listed in Annex I is not a relevant product (Article 2(2)).

The 89 entries split into cattle 8, cocoa 6, coffee 2, oil palm 28, rubber 10, soya 4 and wood 31. Delegated Regulation (EU) 2026/2102 added 18 lines (frozen cattle tongues ex 0206 21 00, soluble coffee 2101 11 00 and 16 oil-palm lines including palm soap), which apply from 30 December 2027. None of the 18 is a wood product, and the other 71 entries carry the dates of Article 38(2) and (3). Removals took effect earlier. Printed products of ex chapter 49 left Annex I on 26 December 2025 (Regulation (EU) 2025/2650). Leather and hides, ex 4010, ex 4016, retreaded and used tyres, soya for sowing, and aircraft and motor-vehicle seats left on 18 September 2026 (Delegated Regulation (EU) 2026/2102).

Table 5. The seven EUDR commodities

Who Must Comply? EUDR Roles: Operator, Micro or Small Primary Operator, Downstream Operator and Trader

Since 26 December 2025 (Regulation (EU) 2025/2650), the EUDR distinguishes four roles: operator (Article 2(15)), micro or small primary operator (2(15a)), downstream operator (2(15b)) and trader (2(17)). Their definitions, in summary:

• Operator (Article 2(15)): places relevant products on the market or exports them in the course of a commercial activity, excluding downstream operators.
• Micro or small primary operator (Article 2(15a)): a subset of operators: a natural person or micro or small undertaking established in a low-risk country that places products of its own production.
• Downstream operator (Article 2(15b)): places on the market or exports relevant products made using relevant products that are all covered by a due diligence statement or a simplified declaration.
• Trader (Article 2(17)): any other person in the supply chain who makes relevant products available on the market.

Downstream operators and traders carry out no due diligence and file no due diligence statement. Non-SME downstream operators and non-SME traders register in the EUDR Information System (Article 5(2)) and verify due diligence only on substantiated concerns (Article 5(6)). Both roles keep the information on their suppliers and customers for at least 5 years (Article 5(4)).

Table 6. Who carries which duty

When a company established outside the Union places products on the market, the first person established in the Union who makes them available is deemed an operator (Article 7). What EU buyers request from producers abroad is set out for EUDR for non-EU suppliers and exporters.

What Does EUDR Compliance Require?

EUDR compliance requires operators to exercise due diligence and submit a due diligence statement before placing a product on the market or exporting it (Article 4(1) and (2)). An authorised representative may submit the statement, but responsibility stays with the operator (Articles 4(3) and 6(1)). Micro or small primary operators file a one-time simplified declaration instead (Article 4a), and downstream operators and traders carry only the Article 5 duties.

EUDR Compliance Steps: Due Diligence, Geolocation and Deforestation-Free Proof

EUDR due diligence has three components under Article 8(2): collecting the Article 9 information, assessing risk against the 14 criteria of Article 10(2) and mitigating any non-negligible risk (Article 11). In order:

1. Information (Article 9): collect the information on each product, including the geolocation of every plot of land.
2. Risk assessment (Article 10): assess the product against criteria (a) to (n) of Article 10(2) and review the assessment at least once a year.
3. Risk mitigation (Article 11): adopt measures until any remaining risk is negligible.

Geolocation uses at least six decimal digits, with polygons for plots of more than 4 hectares (about 9.88 acres) other than cattle; for cattle, it covers every establishment where the animals were kept (Article 2(28)). Deforestation means the conversion of forest to agricultural use, whether human-induced or not (Article 2(3)). Forest means land of more than 0.5 hectares (about 1.24 acres) with trees higher than 5 metres and a canopy cover of more than 10 % (Article 2(4)), and the forest-degradation test applies to wood only (Article 2(13)(b)). Legality covers 8 headings of the law of the country of production (Article 2(40)(a) to (h)).

Simplified due diligence under Article 13 serves products from low-risk countries and is not the simplified declaration of Article 4a: the full statement and the Article 9 information, including geolocation, remain.

Table 7. The compliance process

The EUDR Due Diligence Statement and the EUDR Information System

The due diligence statement (Annex II) is filed in the EUDR Information System before placing or export, and the system returns a reference number and a verification number. Annex II holds points 1, 2, 3, 5 and 6, and a statement can be amended or withdrawn within 72 hours after the reference number is made available (Implementing Regulation (EU) 2024/3084, Article 5(1)). The operator passes the reference number to the downstream operators and traders it supplies (Article 4(7)). Statements are kept for 5 years from submission (Article 4(3)), and due diligence documentation for 5 years (Article 12(5)).

The EUDR Information System is the system of Article 33, run under Implementing Regulation (EU) 2024/3084 as amended by Implementing Regulation (EU) 2026/1565, in force since 17 July 2026. The Commission bears its costs (Implementing Regulation (EU) 2024/3084, Article 18(1)), so filing is free of charge. TRACES is the portal that hosts the system, not its name.

Table 8. Statement and system

How Does EUDR Country Benchmarking Classify Countries as Low, Standard or High Risk?

Implementing Regulation (EU) 2025/1093 classifies 140 countries as low risk and four as high risk (Belarus, North Korea, Myanmar and Russia); every other country is standard risk. The list was published in OJ L, 2025/1093, of 23 May 2025 and applies since 26 May 2025 (Article 29). The class rates only the risk under Article 3(a) that products are not deforestation-free.

The class has two consequences. Operators whose commodities all come from low-risk countries can apply simplified due diligence under Article 13. Competent authorities check each year at least 1 % of the operators, non-SME downstream operators and non-SME traders concerned for low-risk origins, 3 % for standard-risk origins, and 9 % of actors plus 9 % of the quantity for high-risk origins (Article 16(8) to (10)). The band follows the country of production, not the country of export. Standard-risk and high-risk origins both require full due diligence; between them, the class changes the minimum share of checks.

Table 9. EUDR country classes

Implementing Regulation (EU) 2025/1093; check rates under Article 16(8) to (10) as replaced by Regulation (EU) 2025/2650.

Who Enforces the EUDR? Enforcement, Checks, Customs and Penalties

Each Member State enforces the EUDR through one or more competent authorities (Article 14), which check operators, non-SME downstream operators and non-SME traders every year. The Commission's list of competent authorities, updated on 12 October 2026, shows no authority for Greece, Malta and Poland. Customs receive the reference number before release for free circulation or export (Article 26(4)); a downstream operator that exports needs none at customs. The electronic interface between customs and the EUDR Information System is due by 1 December 2029 (Article 28(1)), and until then customs do not check the status of a statement in the system.

Article 25(2)(a) to (f) lists six penalty types: fines, confiscation of products, confiscation of revenues, exclusion from public procurement and public funding for a maximum of 12 months, a temporary market ban, and a ban on simplified due diligence. The maximum fine for legal persons must be at least 4 % of total annual Union-wide turnover in the financial year before the fining decision (Article 25(2)(a)); Member States set the amounts in national law.

As of 24 October 2026, Germany has no EUDR implementing law in force: government bill BT-Drs. 21/8278 of 30 September 2026 had its first reading on 8 October 2026. The Netherlands has an adopted law (Stb. 2024, 242), whose entry into force by royal decree is still open.

Table 10. Enforcement in detail

Every rule on this page is checked against EUR-Lex and Commission sources; see our methodology and fact-checking.

This guide explains the rules; it is not legal advice for an individual case.

How Does the EUDR Connect to the EUTR, FLEGT, Certification and Practical Support?

The EUDR replaces one timber law, builds on a licensing scheme and sits beside voluntary certification and commercial tools, none of which replaces its duties. Each connection below is a bridge to the guide that holds the detail.

The EU Timber Regulation (EUTR) and FLEGT Licences

The EUDR repeals the EU Timber Regulation from 30 December 2026, but the EUTR applies until 31 December 2029 to timber produced before 29 June 2023 and placed on the market from 30 December 2026 (Article 37). A FLEGT licence proves only the legality condition (Article 10(3)); deforestation-free evidence, geolocation and the statement remain. Indonesia issues FLEGT licences since 15 November 2016, and Ghana's licences apply in the EU since 8 October 2025.

Table 11. Predecessor and licensing

Certification and the EUDR: What Schemes Can Prove

No EUDR certificate exists: certification is complementary information under Article 10(2)(n), and the legal output is the reference number or declaration identifier (FAQ 5.7). The operator still assesses what a scheme supplies. What each scheme can and cannot prove is set out under certification and the EUDR.

EUDR Software, Tools and Glossary: What Is Required?

No: software, consultants and certification are never mandatory; the only mandatory IT is the EUDR Information System, free of charge. As of 24 October 2026, no EU or national authority approves EUDR software or providers.

Table 12. Practical support

Frequently Asked Questions About the EUDR

Readers most often ask about EU-grown commodities, the United Kingdom, online buyers, samples and compliance costs.

Does the EUDR Apply to Commodities Produced Inside the EU?

Yes: the Commission considers commodities produced in the Union covered like imports (FAQ 2.4). A farmer or forest owner in a Member State who places Annex I products on the market meets the same three Article 3 conditions as an importer.

Does the EUDR Apply in the United Kingdom, Norway or Switzerland?

Partly: the EUDR applies in the customs territory of the Union (Article 2(34)), which includes Northern Ireland but not Great Britain, as UK government guidance of 17 July 2026 confirms. Norway, Iceland, Liechtenstein and Switzerland are third countries (FAQ 9.13).

Do Consumers Buying Online Have EUDR Obligations?

No: a consumer is never an operator, even when declared as importer, and a purely intermediary marketplace has no obligation, in the Commission's view (Guidance, chapter 2(a); FAQ 3.18 to 3.19).

Are Samples and Used Goods Covered by the EUDR?

Samples of negligible value and quantity and products undergoing tests are excluded by Annex I note (5) since 18 September 2026. Used goods are excluded only on the Annex I lines that carry that note; there is no blanket exemption for second-hand products.

What Does the Commission Estimate EUDR Compliance Costs?

The Commission estimates EUR 2.0 billion a year instead of EUR 8.1 billion (COM(2026) 191, section 5.1, 4 May 2026). It assumes EUR 1,000, 10,000 or 15,000 per company per year (low, central, high) for standard-risk or high-risk sourcing, half that for low-risk sourcing, and EUR 500 per micro or small primary operator.

About EUDR Guide: Independence and Fact-Checking

EUDR Guide is an independent reference, not affiliated with the European Commission, any competent authority or any certification scheme. The page about EUDR Guide explains who publishes the site and how it is funded. Corrections are dated on the page under our editorial policy.