Deforestation-Free Under the EUDR: Forest, Degradation and the 31 December 2020 Cut-Off

Deforestation-free under the EUDR means that a product's commodities were produced on land not subject to deforestation after 31 December 2020 and, for products containing or made using wood, that the wood was harvested without inducing forest degradation after that date (Article 2(13) of Regulation (EU) 2023/1115). Which land changes fail that test, and how is it proven?

The test comes from the EU Deforestation Regulation, also called the "Regulation on deforestation-free products". Article 3(a) makes it the first condition for placing cattle, cocoa, coffee, oil palm, rubber, soya or wood products on the EU market or exporting them.

The rules below cover the Article 2 definitions, forest, deforestation, degradation, the cut-off date, legal clearing, evidence, maps and the dates in force. The four key figures are listed below.

• Cut-off date: 31 December 2020 (Article 2(13)).
• Forest: more than 0.5 hectares (about 1.24 acres), trees higher than 5 metres, canopy cover of more than 10 % (Article 2(4)).
• Degradation test: wood only (Article 2(13)(b)).
• Application: 30 December 2026 (Article 38(2)).

What Does Deforestation-Free Mean? The EUDR Definitions in Article 2

Deforestation-free has two limbs: (a) no deforestation after 31 December 2020 on the land of production, and (b) for wood, no forest degradation induced by the harvest after that date (Article 2(13)). Article 3 makes it the first of three cumulative conditions, beside legality and a due diligence statement or simplified declaration. Points 3 to 13 of Article 2 build the test and are unchanged by Regulations (EU) 2024/3234 and 2025/2650 and Delegated Regulation (EU) 2026/2102. The German term is "entwaldungsfrei", the French "zéro déforestation".

Article 2 holds 42 points in total; the full list sits under EUDR definitions.

What Counts as Forest Under the EUDR?

Forest under the EUDR is land spanning more than 0.5 hectares with trees higher than 5 metres and a canopy cover of more than 10 %, or trees able to reach those thresholds in situ, excluding land predominantly under agricultural or urban use (Article 2(4)).

The Three Forest Thresholds: 0.5 Hectares, 5 Metres, 10 % Canopy

All three forest thresholds must be met at the same time, either today or "in situ" by trees able to reach them (Guidance C/2026/3896, section 11.3). A plot of 0.4 hectares with tall, dense trees is not forest, and neither is a large area of 5-metre trees with 8 % canopy. Land predominantly under agricultural or urban use is excluded even where its trees pass all three thresholds.

Primary, Naturally Regenerating, Planted and Plantation Forest

The EUDR sorts forest into four types that matter for degradation, listed below.

• Primary forest (Article 2(8)): naturally regenerated, native species, no clearly visible human activity.
• Naturally regenerating forest (Article 2(9)): predominantly natural regeneration, including coppice and naturally regenerated introduced species.
• Planted forest (Article 2(10)): planted or seeded trees expected to form more than 50 % of the growing stock at maturity.
• Plantation forest (Article 2(11)): planted forest with one or two species, even age class and regular spacing, excluding forest planted for protection or ecosystem restoration.

Other Wooded Land and Soya in the Cerrado: Not Forest

Other wooded land, with a canopy cover of 5 to 10 %, is not forest and is not protected under the EUDR (Article 2(12)). Converting it, or other non-forest native vegetation such as much of the Brazilian Cerrado, is not deforestation, although it may matter for legality under Article 2(40)(b). Soya chains are covered under EUDR and soya.

What Is Deforestation Under the EUDR?

Deforestation under the EUDR is "the conversion of forest to agricultural use, whether human-induced or not" (Article 2(3)). The cause does not matter: forest lost to fire or storm and then farmed counts, while the conversion to agricultural use decides.

Agricultural Use, Set-Aside Land and Oil Palm or Rubber Plantations

Agricultural use is the use of land for agriculture, including agricultural plantations and set-aside agricultural areas, and for rearing livestock (Article 2(5)). Set-aside land stays agricultural for "generally [ten] years", in the Commission's non-binding wording with the bracket as printed (Guidance, section 11.4(a)). Agricultural plantations include oil palm and all plantations of relevant commodities other than wood, and are not forest (Article 2(6)). The Commission considers that replacing forest with an oil palm or rubber plantation after the cut-off is deforestation, while replanting an existing plantation is not (FAQ Version 5 (April 2026), 4.14). Rubber products are listed under EUDR and rubber.

Agroforestry and Cocoa Under Tree Cover: Agricultural Use, Not Forest

Land predominantly under agroforestry, where crops grow under tree cover, is agricultural use and not forest (Article 2(6); recital 37; Guidance, section 11.4(d)). Cocoa or coffee grown under shade trees counts as an agricultural plantation. Shade-grown chains are covered under EUDR and cocoa. The converse also holds: small-scale production of side products such as coffee in a forest, without detrimental effect on the forest habitat, does not make agricultural use predominant (Guidance, section 11.4(b)).

Conversion to Roads, Settlements or Renewables: Not Deforestation

Conversion of forest to non-agricultural uses is not deforestation, because Article 2(3) covers only agricultural use. The Guidance lists roads, electricity lines, settlements, non-agricultural industrial sites, renewable energy, biodiversity restoration, forest fire prevention, animal-welfare structures and invasive alien species management (section 11.2). Wood legally harvested to build a road is compliant (FAQ 4.11), but the legality condition still applies.

What Is Forest Degradation and Why Does It Apply Only to Wood?

Forest degradation is "structural changes to forest cover", taking the form of the conversion of (a) primary or naturally regenerating forests into plantation forests or other wooded land, or (b) primary forests into planted forests (Article 2(7)).

The degradation limb sits only in Article 2(13)(b), which covers products that contain or have been made using wood. Wood must pass both limbs, deforestation and degradation (FAQ 4.3), while products of cattle, cocoa, coffee, oil palm, rubber or soya that contain no wood are tested on limb (a) alone. Wood products and species rules are under EUDR and wood.

The 31 December 2020 Cut-Off Date: Unchanged by Every EUDR Delay

The cut-off date is 31 December 2020, fixed in Article 2(13) and never moved by Regulation (EU) 2024/3234, Regulation (EU) 2025/2650 or Delegated Regulation (EU) 2026/2102. Each EUDR delay moved application dates only.

The cut-off is not the production limit: products produced before entry into force on 29 June 2023 are outside the Regulation (Article 1(2), Article 38(1)), and earlier timber falls under the transition of Article 37. Forest cleared in 2022 for a crop harvested in 2027 fails the test; forest cleared in 2019 does not fail limb (a).

The Commission considers that the check looks backwards at whether the land was forest on the cut-off date (FAQ 5.12). Recital 46 grounds the date in the Sustainable Development Goals, the New York Declaration on Forests and the precautionary principle. The general review due by 30 June 2030 assesses the cut-off date together with other wooded land (Article 34(2)(g)).

Is Legal Deforestation Deforestation-Free? The Brazil Forest Code Example

No: conversion of forest after 31 December 2020 fails Article 3(a) whatever national law permits, because the three Article 3 conditions are cumulative (FAQ 1.29). Legality under Article 3(b) is a separate test.

The two conditions also differ in reach: the Commission considers that illegality in one area of an estate makes commodities from other areas of the same property non-compliant (FAQ 1.15).

Brazil's Forest Code (Lei nº 12.651/2012, Article 12) sets a Reserva Legal of 80 % in forest, 35 % in cerrado and 20 % in campos gerais within the Legal Amazon, and 20 % elsewhere. Article 12 allows lawful clearing beyond that reserve, which still fails the EUDR where the land was forest on 31 December 2020. Its 22 July 2008 consolidated-area date is not the EUDR cut-off. Brazilian sourcing is covered under EUDR and Brazil.

How Do Operators Prove a Product Is Deforestation-Free?

Operators, including micro or small primary operators, collect the deforestation-free evidence before placing or export. Since 26 December 2025, downstream operators and traders carry out no due diligence and file no due diligence statement (Article 5).

Article 9(1)(g): Adequately Conclusive and Verifiable Information

Article 9(1)(g) requires "adequately conclusive and verifiable information that the relevant products are deforestation-free". The operator keeps it for 5 years from placing on the market or export (Article 9(1)). An operator that cannot obtain the information does not place or export the product (Article 4(4)(c)).

EUDR Geolocation and the Plot-Level Check

Any deforestation or forest degradation on a plot automatically disqualifies all relevant commodities and products from that plot (Article 9(1)(d)). Point and polygon rules are under EUDR geolocation. Under simplified due diligence, the Commission considers that the geolocation can meet the Article 9(1)(g) evidence item (FAQ 5.1). Mass balance is not allowed: segregation is required at every step, although full identity preservation is not (FAQ 1.4).

Forest Maps and Public Tools for the EUDR Risk Assessment

Forest maps support the deforestation-free check but decide nothing: the EU Observatory is "non-exclusive, non-mandatory and carries no legal value" (Guidance, section 11.5), is free of charge, and its legal anchor is recital 31, not an operative article. Operators may use any maps or data.

A plot inside mapped forest is not automatically non-compliant, and a plot outside it is not presumed compliant; authorities also consider plots that the map does not show as forest (FAQ 9.10). Global maps typically reach around 85 % accuracy and national maps up to 90 %, and no map is a reference map (FAQ 9.10.2). GFC2020 is not intended as a definitive source of information for compliance (FAQ 9.10.1). Map results feed the EUDR risk assessment. JRC report JRC141229 of 22 May 2025 describes the EUDR extension of the IMPACT Toolbox for viewing and intersecting plot data.

Deforestation-Free Timeline: Dates in Force and the 2030 Review

The deforestation-free test applies from 30 December 2026 (Article 38(2)) and from 30 June 2027 for operators that are natural persons or micro or small undertakings established as such by 31 December 2024 (Article 38(3)); products in the Annex to Regulation (EU) No 995/2010 apply from 30 December 2026. Every date in force is on the EUDR timeline. No further delay is proposed as of 24 October 2026.

Every rule on this page is checked against the consolidated text of Regulation (EU) 2023/1115; see our methodology and fact-checking.

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

How Does Deforestation-Free Connect to EUDR Compliance and Due Diligence?

Deforestation-free is Article 3(a), one of three cumulative conditions that every product placed, made available or exported must meet. Deforestation-free is one condition of EUDR compliance.

The Commission positions quoted here come from the Guidance (Official Journal C, 20 July 2026) and the FAQ (April 2026), both non-binding (Article 15(5)). A "deforestation-free" label on a consumer product is a marketing claim, covered at greenwashingdirective.com, not the Article 2(13) test.

Operators show the condition through due diligence: information under Article 9, risk assessment under Article 10 and risk mitigation under Article 11 (Article 8(2)). The three steps are set out under EUDR due diligence.

How Does Deforestation-Free Relate to the EUDR Legality Requirement?

Legality is the separate Article 3(b) condition: production in accordance with the relevant legislation of the country of production. Its eight headings are under EUDR legality requirement.

Deforestation-Free FAQ

Five further questions concern scope, certification, FLEGT, risk classes and satellite tools. More answers are in the EUDR FAQ.

Which Products Must Be Deforestation-Free?

The products listed in Annex I that contain, have been fed with or were made using cattle, cocoa, coffee, oil palm, rubber, soya or wood must be deforestation-free (Article 2(1) and 2(2)). Every code is listed in EUDR Annex I.

Does Certification Prove a Product Is Deforestation-Free?

No: a certificate is complementary information under Article 10(2)(n), and no EUDR certificate exists (FAQ 5.7). The operator still collects the Article 9(1)(g) evidence. What schemes prove is under certification and the EUDR.

Does a FLEGT Licence Prove a Product Is Deforestation-Free?

No: a FLEGT licence counts only for legality (Article 10(3)); deforestation-free evidence, the Article 9 information and the due diligence statement remain required. What FLEGT licences prove is set out there.

Does a Low-Risk Country Classification Make Products Deforestation-Free?

No: the classes of Implementing Regulation (EU) 2025/1093 rate the Article 3(a) risk only (Article 29(1)) and open simplified due diligence, which still needs geolocation and a due diligence statement (Article 13(1)). The low-risk country list names 140 countries.

Do I Need Satellite Imagery or Software to Prove Deforestation-Free?

No: the Regulation imposes no specific satellite imagery tool and no resolution threshold (FAQ 5.18), and the only mandatory IT is the free EUDR Information System (Implementing Regulation (EU) 2024/3084, Article 18(1)). What platforms do is covered under EUDR software; none is mandatory.