EUDR Compliance: Step-by-Step Process Under 2023/1115

EUDR compliance under Regulation (EU) 2023/1115: the Article 3 conditions, who must comply by 30 December 2026, and the steps operators follow in order.

The Regulation (OJ L 150, 9.6.2023, 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; its core obligations apply from 30 December 2026.

Who carries which duty depends on the role. The EU Deforestation Regulation has distinguished four roles since 26 December 2025: operator, micro or small primary operator, downstream operator and trader. Only operators exercise due diligence and submit a due diligence statement (DDS) in the EUDR Information System before placing or export (Article 4(2)); micro or small primary operators file a one-time simplified declaration, and downstream operators and traders keep supplier and customer information. The duties run in 13 steps, and each of the eight compliance topics in Table 1 has its own page.

Table 1. The 8 EUDR compliance topics

#	Topic	What it answers	Key rule
1	EUDR due diligence	How the due diligence system works	Three components (Art. 8(2)); system kept up to date and reviewed yearly (Art. 12)
2	EUDR information requirements	What to collect per product	8 items, Art. 9(1)(a) to (h); kept 5 years
3	EUDR geolocation	How to locate plots of land	At least 6 decimal digits; polygons above 4 ha, not for cattle (Art. 2(28))
4	EUDR traceability	How to link products to plots	Segregation required, mass balance not allowed (FAQ Version 5 (April 2026), 1.4)
5	deforestation-free under the EUDR	Which land qualifies	Forest test (Art. 2(4)); cut-off 2020-12-31 (Art. 2(13))
6	EUDR legality requirement	Which laws of the producer country count	8 headings, Art. 2(40)(a) to (h)
7	EUDR risk assessment and risk mitigation	How to assess and reduce risk	14 criteria, Art. 10(2)(a) to (n); measures under Art. 11
8	simplified due diligence under the EUDR	When Articles 10 and 11 fall away	All origin low risk, negligible mixing risk (Art. 13)

What Is EUDR Compliance?

EUDR compliance is meeting the three cumulative conditions of Article 3 of Regulation (EU) 2023/1115 for every product in scope, from 30 December 2026.

What Are the Three Conditions of Article 3 of Regulation (EU) 2023/1115?

Article 3 allows placing, making available and export only if a relevant commodity or product meets three conditions, listed below.

Deforestation-free: no deforestation after the cut-off date of 31 December 2020 (Article 2(13)); for wood, also no forest degradation.
Legal: produced in accordance with the relevant legislation of the country of production (8 headings, Article 2(40)).
Covered: covered by a due diligence statement or a simplified declaration (point (c) as replaced by Regulation (EU) 2025/2650 from 26 December 2025).

The conditions are cumulative: a product that fails one of them cannot be placed on the market (Guidance C/2026/3896, section 6; FAQ 1.29). Point (c) is the procedural condition, and since 26 December 2025 it accepts the simplified declaration alongside the DDS. Every article and annex of Regulation (EU) 2023/1115 is explained in its consolidated version of 18 September 2026.

Is There an Official EUDR Compliance Checklist?

No: the Commission prescribes no checklist and calls due diligence "not a tick-the-box exercise" (FAQ 5.16). Its Green Forum page adds: "There is no fixed format or set list of questions." The Guidance (third edition, OJ C of 20 July 2026) and FAQ Version 5 (April 2026) are not binding (Article 15(5)). The Regulation fixes the consequence of a gap instead: without the required information, no placing or export (Article 4(4)(c); FAQ 1.27).

Who Must Comply With the EUDR, and by When?

Every company that places, makes available or exports an Annex I product in the course of a commercial activity must comply from 30 December 2026; its role, its size and the origin of its products set the duties. The Regulation applies in the customs territory of the Union (Article 2(34)). Producers outside it supply the evidence their EU customers request, as set out for non-EU suppliers and exporters.

Which EUDR Role Do You Have?

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

Operator: places relevant products on the market or exports them in a commercial activity, other than a downstream operator.
Micro or small primary operator: a natural person or micro or small undertaking in a low-risk country placing its own production; the rules for micro or small primary operators replace the DDS with a simplified declaration.
Downstream operator: places or exports products made from relevant products all covered by a DDS or simplified declaration.
Trader: any other person in the supply chain making relevant products available.

Table 2 compares their obligations.

Table 2. Who carries which EUDR obligation

Obligation	Operator	Micro or small primary operator	Downstream operator	Trader
Due diligence	Yes (Art. 8)	Simplified regime (Art. 4a)	No	No
Statement	DDS (Art. 4(2), Annex II)	Simplified declaration (Art. 4a, Annex III)	None	None
Registration (roles in the EUDR Information System)	Yes	Yes	Non-SME only (Art. 5(2))	Non-SME only (Art. 5(2))
Information	Art. 9	Annex III	Art. 5(3)	Art. 5(3)
Records	5 years (Art. 4(3), 12(5))	See Article 4a	At least 5 years (Art. 5(4))	At least 5 years (Art. 5(4))
Compliance officer and independent audit function	Non-SME (Art. 11(2))	No	No	No
Annual public report	Non-SME (Art. 12(3))	No	No	No
Check base (Art. 16)	Yes	See Article 4a	Non-SME	Non-SME

Articles 4, 4a, 5, 11, 12 and 16 as amended by Regulation (EU) 2025/2650.

One boundary rule completes the roles: a company that makes a product from inputs not covered by a DDS or simplified declaration is an operator for those inputs (Article 2(15b); Guidance, section 9).

When Do the EUDR Compliance Obligations Apply?

The obligations apply from 30 December 2026; operators that are natural persons or micro or small undertakings established as such by 31 December 2024 apply them from 30 June 2027, except for products in the Annex to Regulation (EU) No 995/2010, which apply from 30 December 2026 (Article 38(2) and (3), as replaced by Regulation (EU) 2025/2650). The date covers Articles 3 to 13, 16 to 24, 26, 31 and 32 (Table 3).

Table 3. When EUDR compliance applies

Who or what	From	Provision
Operators, downstream operators and traders	2026-12-30	Art. 38(2)
Operators that are natural persons or micro or small undertakings established as such by 31 December 2024	2027-06-30	Art. 38(3)
Same operators, products in the Annex to Regulation (EU) No 995/2010	2026-12-30	Art. 38(3)
18 Annex I lines added by Delegated Regulation (EU) 2026/2102	2027-12-30	Delegated Regulation (EU) 2026/2102
Deforestation cut-off date	2020-12-31	Art. 2(13)

Added lines: frozen cattle tongues (ex 0206 21 00), soluble coffee (2101 11 00), 16 oil-palm lines.

A micro undertaking does not exceed at least two of three limits: balance sheet EUR 450,000, net turnover EUR 900,000, average employees 10; a small undertaking EUR 5 million, EUR 10 million and 50 (Directive 2013/34/EU as amended by Delegated Directive (EU) 2023/2775, values on 31 December 2024, per legal entity).

The 13 Steps of EUDR Compliance: Annex I, Roles, Dates, Country Risk and the Due Diligence Statement

EUDR compliance runs in 13 steps derived from the articles: steps 1 to 5 decide whether and when the rules apply, steps 6 to 10 follow Article 8(2), and steps 11 to 13 cover the statement and ongoing duties.

Table 4. The 13 steps of EUDR compliance

#	Step	Who	Provision	Owner page
1	Check Annex I	All roles	Art. 1, Annex I	EUDR Annex I
2	Check the production date	All roles	Art. 1(2)	EUDR transitional stock
3	Identify the role	All roles	Art. 2(15) to (17), Art. 7	EUDR roles
4	Find the application date	All roles	Art. 38	EUDR dates in force
5	Check micro or small primary operator status	Producers in low-risk countries	Art. 2(15a), Art. 4a	Micro or small primary operators
6	Set up a due diligence system	Operators	Art. 8, Art. 12(1)	EUDR due diligence
7	Collect the Article 9 information	Operators	Art. 9(1)	EUDR information requirements
8	Test simplified due diligence	Operators	Art. 13	EUDR country benchmarking
9	Assess the risk	Operators	Art. 10	EUDR risk assessment
10	Mitigate the risk	Operators	Art. 11	EUDR risk mitigation
11	Submit the DDS or simplified declaration	Operators	Art. 4(2), Art. 4a, Annexes II and III	EUDR due diligence statement
12	Pass on the reference number	Operators	Art. 4(7), Art. 26(4)	EUDR reference number
13	Keep records, review, report	Operators	Art. 4(3), 4(5), Art. 12	EUDR due diligence

This guide's order, derived from the articles; the Commission prescribes no checklist (FAQ 5.16).

Step 1: Check Whether Your Commodity and Product Are in Annex I

A product is in scope only if its CN code is listed in Annex I: 89 entries, seven commodities, no de minimis threshold (FAQ 2.3). Printed products left Annex I on 26 December 2025; leather and hides, ex 4010, ex 4016, retreaded and used tyres, soya for sowing, and aircraft and motor-vehicle seats on 18 September 2026.

The products derived from the seven EUDR commodities (cattle, cocoa, coffee, oil palm, rubber, soya, wood) are listed by commodity.

Step 2: Check the Production Date

Products produced before 29 June 2023 are outside the EUDR (Article 1(2)); such EUTR timber placed from 30 December 2026 stays under the EUTR until 31 December 2029 (Article 37). This date is not the deforestation cut-off.

Transitional stock, placed on the market before 30 December 2026, needs no DDS, only evidence of that placing, in the Commission's view (FAQ 9.1 and 9.2); the evidence rules sit under EUDR transitional stock.

Step 3: Identify Your Role in the Supply Chain

The role is fixed per product and transaction, and the first EU-established person making available a product placed by a non-EU operator is deemed an operator (Article 7).

Step 4: Find Your Application Date

Operators that are natural persons or micro or small undertakings check whether the product is listed in the Annex to Regulation (EU) No 995/2010: if so, the date stays 30 December 2026 (Article 38(3)).

Step 5: Check Whether You Are a Micro or Small Primary Operator

A micro or small primary operator is a natural person or micro or small undertaking established in a low-risk country that places its own production (Article 2(15a)), and it files a one-time simplified declaration with the Annex III information instead of a DDS (Article 4a). That declaration is not Article 13 simplified due diligence; a postal address may replace geolocation (Article 4a(5)).

Step 6: Set Up a Due Diligence System

Operators set up and keep up to date a due diligence system (Article 12(1)) that runs the three components of Article 8(2): information collection (Article 9), risk assessment (Article 10) and risk mitigation (Article 11). Due diligence comes before placing or export (Article 4(1)).

Step 7: Collect the Article 9 Information, Including Geolocation

Article 9(1) requires 8 items of information with evidence: description (for wood, species names), quantity, country of production, geolocation of all plots with the production date or range, suppliers, customers, and verifiable evidence of deforestation-free status and of legality. Geolocation uses at least six decimal digits, polygons for plots over 4 hectares except cattle (Article 2(28)). Missing information means no placing (Article 4(4)(c)).

Step 8: Test Whether Simplified Due Diligence Applies

Operators skip Articles 10 and 11 only when, after assessing supply chain complexity and mixing risk, they have ascertained that all commodities were produced in low-risk countries (Article 13(1)). Implementing Regulation (EU) 2025/1093 lists 140 low-risk and 4 high-risk countries (Belarus, North Korea, Myanmar, Russia); the rest are standard risk. Article 9 information, the DDS and the Article 12 system remain (FAQ 1.28).

Step 9: Assess the Risk Against the Article 10 Criteria

Operators assess each product against the 14 criteria of Article 10(2)(a) to (n), document the assessment and review it at least once a year (Article 10(4)).

Step 10: Mitigate Any Non-Negligible Risk

Where risk is not negligible, operators adopt measures until the risk is negligible, such as additional information, independent surveys or audits, or support for suppliers (Article 11(1)); otherwise the product is not placed or exported (Article 4(4)(b)). Non-SME operators also keep a compliance officer at management level and an independent audit function (Article 11(2)).

Step 11: Submit the Due Diligence Statement or Simplified Declaration

Operators submit the DDS (Annex II) in the EUDR Information System before placing or export (Article 4(2)) and receive a reference number and a verification number (Implementing Regulation (EU) 2024/3084, Article 7). Annex II holds points 1, 2, 3, 5 and 6 (point 4 deleted by Regulation (EU) 2025/2650), and a DDS can be amended or withdrawn within 72 hours after the reference number is made available (Implementing Regulation (EU) 2024/3084, Article 5(1)). An authorised representative may submit, but the operator stays responsible (Articles 4(3) and 6(1)).

Step 12: Pass On the Reference Number

The reference number goes to customs before release for free circulation or export (Article 26(4)) and to the downstream operators and traders supplied (Article 4(7)); a downstream operator exporting needs none at customs. The verification number need not be passed on (FAQ 3.6.1); the EUDR reference number has its own format rules.

Step 13: Keep Records, Review Every Year and Report

Operators keep each DDS record 5 years from submission (Article 4(3)), keep all due diligence documentation at least 5 years (Article 12(5)) and review the system at least once a year (Article 12(2)). New information on risk goes immediately to the competent authorities and to downstream operators and traders (Article 4(5)). Non-SME operators report publicly every year (Article 12(3)), first for 2027 (FAQ 5.14).

What Do Downstream Operators and Traders Have to Do?

Since 26 December 2025, downstream operators and traders carry out no due diligence and submit no DDS; they hold the information of Article 5(3) instead (Regulation (EU) 2025/2650). Before placing, making available or exporting, they possess the name, trade name or trade mark, postal, email and web address of each supplier and customer, and the reference numbers or declaration identifiers, but only where the supplier is an operator (Article 5(1) and (3)). New information pointing to a non-compliant product, including substantiated concerns, goes immediately to the competent authorities and customers (Article 5(5)). On substantiated concerns, non-SME downstream operators and non-SME traders verify that due diligence was exercised (Article 5(6)).

A downstream operator has no duty to check the due diligence of its suppliers (Guidance, section 4(d)). The full duties are set out for downstream operators under the EUDR and EUDR traders.

What Enforcement, Checks and Penalties Apply If You Do Not Comply?

Competent authorities check at least 1 %, 3 % or 9 % of operators, non-SME downstream operators and non-SME traders each year, by the risk class of the country of production (Article 16(8) to (10), as replaced by Regulation (EU) 2025/2650). For high-risk origins, EUDR enforcement also covers 9 % of the quantity of each relevant product; authorities and customs controls are set out under EUDR enforcement.

No grace period applies: the six-month grace period proposed in COM(2025) 652 of 21 October 2025 was never adopted, so checks start with the obligations, on 30 December 2026 or, for deferred operators, on 30 June 2027.

EUDR penalties follow a catalogue of six types in Article 25(2)(a) to (f): fines, confiscation of products, confiscation of revenues, exclusion from public procurement and public funding for at most 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 (Article 25(2)(a)).

Member States set the amounts in national law; each penalty type is explained under EUDR penalties.

Do You Need Software, a Consultant or a Certificate to Comply?

No: the EUDR requires none of them; the only mandatory system is the EUDR Information System, paid for by the Commission (Implementing Regulation (EU) 2024/3084, Article 18(1)). As of 24 October 2026, no EU or national authority approves EUDR software or providers, and responsibility stays with the operator when it uses tools, consultants or an authorised representative (Articles 4(3) and 6(1)).

No EUDR certificate exists either. The legal output of compliance is the DDS reference number or the declaration identifier of a simplified declaration (FAQ 5.7), and a certification scheme supplies complementary information under Article 10(2)(n) that the operator still assesses. What each scheme proves is set out under certification and the EUDR.

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 EUDR Compliance Connect to Costs, Delays and Earlier Rules?

EUDR compliance depends on three outside facts: the Commission's cost estimate, the dates set by the amending acts and the replacement of the EU Timber Regulation.

What Does EUDR Compliance Cost?

The Commission estimates the annual cost of EUDR compliance at EUR 2.0 billion instead of EUR 8.1 billion under the 2023 text, about 75 % lower (COM(2026) 191, section 5.1, 4 May 2026). Its central assumption is EUR 10,000 per company per year for standard-risk or high-risk sourcing, half that for low-risk sourcing, and EUR 500 per year for a micro or small primary operator.

Is Another EUDR Delay Planned?

No: as of 24 October 2026 no proposal to postpone the EUDR again exists. Each earlier EUDR delay is documented with the act that decided it.

What Did the 2025 Simplification Change for Compliance?

Regulation (EU) 2025/2650, in force since 26 December 2025, redefined the roles, replaced Article 3(c) and added the simplified declaration for micro or small primary operators. The changes and the 2026 review are covered under EUDR simplification.

How Does EUDR Compliance Relate to the EUTR?

The EUDR repeals the EUTR with effect from 30 December 2026, but the EUTR still applies until 31 December 2029 to timber produced before 29 June 2023 and placed on the market from 30 December 2026 (Article 37). The transition is explained under EU Timber Regulation (EUTR).

Does a FLEGT Licence Prove EUDR Compliance?

No: a FLEGT licence covers the Article 3(b) legality condition only (Article 10(3)), so deforestation-free evidence, geolocation and the DDS remain. The licensing countries are listed under FLEGT licences and the EUDR.

What Do Operators Most Often Ask About EUDR Compliance?

Operators most often ask about SME duties, EU-grown commodities and Great Britain. More answers to the questions operators, traders and suppliers ask are collected on the FAQ page.

Do SME Operators Have Lighter EUDR Duties?

No: SME operators carry the full due diligence and submit their own DDS, because Regulation (EU) 2025/2650 deleted the SME derogation of Article 4(8). Their relief is timing: operators that are natural persons or micro or small undertakings established as such by 31 December 2024 apply the rules from 30 June 2027; products in the Annex to Regulation (EU) No 995/2010 apply from 30 December 2026.

Are Commodities Grown in the EU Covered?

Yes: commodities produced in the Union are covered like imports, in the Commission's view (FAQ 2.4). All 27 Member States are low-risk countries under Implementing Regulation (EU) 2025/1093, so EU-origin products can qualify for simplified due diligence when the Article 13 conditions are met.

Does the EUDR Apply in Great Britain?

No: the EUDR applies in the customs territory of the Union (Article 2(34)), which includes Northern Ireland but not Great Britain. Norway, Iceland, Liechtenstein and Switzerland are third countries (FAQ 9.13), and the rules on where the EUDR applies cover the remaining territorial cases.

EUDR Compliance: The Complete Step-by-Step Process for Operators, Downstream Operators and Traders

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