EUDR FAQ: Answers to the Questions Operators, Traders and Suppliers Ask

This EUDR FAQ answers 42 recurring questions on Regulation (EU) 2023/1115, from the 30 December 2026 start to penalties, and explains the Commission's non-binding FAQ Version 5 (April 2026). Which answer fits an operator, a trader or a supplier outside the EU?

The EU Deforestation Regulation has applied in part since 29 June 2023, and each answer below names its article.

The ten answer groups and their key values are compared below.

This guide groups the questions in its own order; the Commission FAQ has ten sections of its own.

What Is the Commission's EUDR FAQ, Version 5 (April 2026)?

The Commission's EUDR FAQ is "Implementation of the EU Deforestation Regulation: Frequently Asked Questions", Version 5 of April 2026, a 95-page document. Its Commission page is dated 21 August 2026, and its 10 sections are listed below.

• Sections 1 to 5: Traceability, Scope, Subjects of obligations, Definitions, Due diligence.
• Sections 6 to 10: Benchmarking and partnerships, Information System, Timelines, Other questions, Penalties.

Is the EUDR FAQ Binding, and How Does It Differ From the Guidance?

No: FAQ Version 5 is "a working document drafted by the Commission services" and "is not legally binding". The Guidance, Commission Notice C/2026/3896 (third edition, 20 July 2026), is equally non-binding (Article 15(5)); both are indexed under EUDR guidance.

What Changed in FAQ Version 5?

FAQ Version 5 replaces the fourth iteration of April 2025 and marks each change as (UPDATED) or (NEW). New answers cover online sales (FAQ Version 5 (April 2026), 3.17 to 3.19), cattle roles (1.26) and substantiated concerns (4.15).

Which FAQ Version 5 Answers Are Already Outdated?

Four FAQ Version 5 passages predate acts adopted in July 2026, as listed below.

• FAQ 2.7, 2.8.1, 2.13 and 2.14 call the Annex I act a draft; it is Delegated Regulation (EU) 2026/2102.
• Implementing Regulation (EU) 2024/3084, called "under amendment", was amended by Implementing Regulation (EU) 2026/1565.
• FAQ 7.24 uses "HS 1201" for soya beans; Annex I reads 1201 90 00.
• FAQ 1.25 cites live cattle as 0102 21 and 0102 29; Annex I reads "ex 0102".

Status and Dates: When Does the EUDR Apply?

The EUDR applies from 30 December 2026, with two later dates.

Which EUDR Dates Are in Force?

Articles 3 to 13, 16 to 24, 26, 31 and 32 apply from 30 December 2026 (Article 38(2)). Operators that are natural persons or micro or small undertakings established as such by 31 December 2024 follow from 30 June 2027 (Article 38(3)); products in the Annex to Regulation (EU) No 995/2010 from 30 December 2026. The 18 lines added in 2026 apply from 30 December 2027, as listed with every date in force.

Is There Another EUDR Delay or a Grace Period?

No: no further delay is proposed as of 24 October 2026, and the six-month grace period proposed in COM(2025) 652 of 21 October 2025 was never adopted. Regulation (EU) 2025/2650 set the current dates, and each EUDR delay is dated with its decision.

What Did the EUDR Simplification of 2025 Change?

Regulation (EU) 2025/2650, in force since 26 December 2025, created four roles, freed downstream operators and traders from statements (Article 5), added the Article 4a simplified declaration and removed printed products (ex 49). The review COM(2026) 191 of 4 May 2026 proposes no new law; see EUDR simplification.

What Happens to Products Produced Before 29 June 2023?

Products produced before 29 June 2023 are outside the EUDR (Article 1(2)). Stock placed on the market before 30 December 2026 needs no statement, only evidence of that placing, and its export uses the conventional number 99EU9999999999 (FAQ 9.1, 9.2). Proof rules are under EUDR transitional stock.

The Regulation: What Is the EUDR and Where Is the Text?

The EUDR is Regulation (EU) 2023/1115, directly applicable and consolidated on 18 September 2026.

What Does EUDR Stand For?

EUDR stands for EU Deforestation Regulation, Regulation (EU) 2023/1115 (OJ L 150, 9.6.2023, p. 206), in force since 29 June 2023. It is "binding in its entirety and directly applicable in all Member States", so national laws designate authorities and set penalties.

Where Is the Consolidated Text of Regulation (EU) 2023/1115?

The consolidated text of 18 September 2026 (CELEX 02023R1115-20260918) includes Regulations (EU) 2024/3234 and 2025/2650 and Delegated Regulation (EU) 2026/2102. The 39 articles and Annexes I to III of Regulation (EU) 2023/1115 are explained one by one.

Scope: Which Products and Places Does the EUDR Cover?

The EUDR covers 89 Annex I entries in the customs territory of the Union.

Which Products Are in EUDR Annex I?

Annex I lists 89 entries: cattle 8, cocoa 6, coffee 2, oil palm 28, rubber 10, soya 4 and wood 31, 18 of them from 30 December 2027. No volume threshold exists (FAQ 2.3), and every code of EUDR Annex I is listed.

Is Packaging Covered by the EUDR?

Packaging sold in its own right is covered; packing classified with the product it carries is not (FAQ 2.5). Annex I excludes single-use packing on ex 4401, ex 4405, ex 4415, ex 4416 and ex 48, as explained under EUDR and wood and paper packaging.

Which EUDR Exemptions Apply to Samples, Used Goods and Recycled Material?

Three narrow exemptions apply: samples of negligible value and quantity (Annex I, note (5), since 18 September 2026), used goods only on lines carrying that exclusion, and goods made entirely from end-of-life material, by-products excepted. All carve-outs are under EUDR exemptions.

Does the EUDR Apply in the UK, Northern Ireland and Switzerland?

The EUDR applies in Northern Ireland but not in Great Britain (Defra guidance of 17 July 2026), because it covers the customs territory of the Union (Article 2(34)). Norway, Iceland, Liechtenstein and Switzerland are third countries (FAQ 9.13), as set out under where the EUDR applies.

Commodities: Which Commodities and Derived Products Are Covered?

Seven relevant commodities and their Annex I derived products are covered.

Which Seven Relevant Commodities Does the EUDR Cover?

The seven relevant commodities are cattle, cocoa, coffee, oil palm, rubber, soya and wood (Article 2(1)), with bamboo and rattan excluded. Products of all seven relevant commodities are listed by commodity.

Is Coffee, Including Soluble Coffee, Covered by the EUDR?

Yes: coffee under heading 0901 is covered from 30 December 2026, and soluble coffee (2101 11 00) from 30 December 2027 (Delegated Regulation (EU) 2026/2102). Instant mixes and coffee beverages are not listed; the lines are set out under EUDR and coffee.

Is Chocolate Covered Under the EUDR Cocoa Rules?

Yes: chocolate (1806) is one of the cocoa headings 1801 to 1806, and due diligence concerns only its cocoa inputs (Guidance C/2026/3896, section 9). All six headings are under EUDR and cocoa.

Are Oil Palm Derivatives and Palm Soap Covered?

Yes: oil palm has 28 lines, 12 from 30 December 2026 and 16, including palm soap (ex 3401 11 00, ex 3401 20), from 30 December 2027. Margarine (1517) is not listed (FAQ 2.1); every line is under EUDR and oil palm.

Which Wood Products Does the EUDR Cover?

Wood has 31 Annex I entries, from fuel wood, logs and sawn wood (ex 4401 to ex 4421) to pulp and paper (ex 47, ex 48), wooden seats, furniture and prefabricated buildings. Printed products (ex 49) left on 26 December 2025; each entry is under EUDR and wood.

Are Tyres, Leather and Soya Products Still Covered?

New tyres and soya products are covered; leather and retreaded or used tyres are not. Since 18 September 2026 (Delegated Regulation (EU) 2026/2102), leather, ex 4010, ex 4016, retreaded and used tyres and soya for sowing are out; ex 4011, ex 4012 90 30, ex 4013 and soya under 1201 90 00, 1208 10, 1507 and 2304 stay in. Tyre lines are under EUDR and tyres.

Roles: Who Carries Which EUDR Obligation?

Four roles exist since 26 December 2025, and only operators file statements.

Am I an Operator, Downstream Operator or Trader?

The role follows Article 2: an operator places relevant products on the market or exports them (point 15), a micro or small primary operator is a subset of operator (15a), a downstream operator places or exports products made from covered products (15b), and a trader makes them available (17). The operator, downstream operator or trader tests have examples.

Do Downstream Operators and Traders File a Due Diligence Statement?

No: since 26 December 2025, downstream operators and traders do no due diligence and file no statement (Article 5). They keep supplier records, with reference numbers "only in the event that their supplier is an operator" (Article 5(3)), and non-SME ones register (Article 5(2)); see downstream operators under the EUDR.

What Is an EUDR 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 directly (Article 2(15a)). It files a one-time simplified declaration (Article 4a, Annex III), not Article 13 simplified due diligence; see EUDR micro or small primary operators.

Do SMEs Get More Time Under the EUDR?

Operators that are natural persons or micro or small undertakings established as such by 31 December 2024 start on 30 June 2027 (Article 38(3)); products in the Annex to Regulation (EU) No 995/2010 from 30 December 2026. Size: not exceeding at least two of three limits, balance sheet EUR 450,000 or 5 million, turnover 900,000 or 10 million, 10 or 50 employees (Directive 2013/34/EU as amended by Delegated Directive (EU) 2023/2775, values on 31 December 2024); see EUDR for SMEs.

What Do Non-EU Suppliers and Exporters Have to Do?

Non-EU suppliers have no EUDR obligation when selling to an EU importer, who is the operator and asks them for Article 9(1) information such as geolocation (FAQ 3.10.2). Typical requests are under EUDR for non-EU suppliers and exporters.

Compliance: What Must Operators Do?

Operators exercise due diligence and file a statement before placing or export.

What Are the Three Steps of EUDR Due Diligence?

The three steps are information collection (Article 9), risk assessment against 14 criteria (Article 10(2)(a) to (n)) and risk mitigation (Article 11), for operators only. Records of EUDR due diligence are kept for 5 years (Article 12(5)).

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). This guide orders the steps itself in the EUDR compliance process.

What Does Deforestation-Free Mean, and What Is the Cut-Off Date?

Deforestation-free means produced on land not deforested after 31 December 2020, and for wood also harvested without inducing forest degradation (Article 2(13)). Forest is more than 0.5 hectares (about 1.24 acres) with trees higher than 5 metres and canopy cover above 10 % (Article 2(4)); see deforestation-free under the EUDR.

What Geolocation Does the EUDR Require?

The EUDR requires latitude and longitude with at least six decimal digits for every plot, and polygons for plots of more than four hectares (about 9.88 acres) other than cattle (Article 2(28)). Cattle get a point per establishment, as set out under EUDR geolocation.

Is Mass Balance Allowed Under EUDR Traceability Rules?

No: mass balance is not allowed, because segregation is required at every step, although full identity preservation is not (FAQ 1.4). Mixing rules are set out under EUDR traceability.

What Goes Into a Due Diligence Statement, and Can It Be Changed?

An operator files the statement before placing or export (Article 4(2)), with Annex II points 1, 2, 3, 5 and 6. The due diligence statement can be amended or withdrawn within 72 hours after its reference number is made available (Article 5(1) of Implementing Regulation (EU) 2024/3084).

Where Is a Statement Filed, and Does the EUDR Information System Cost Anything?

A statement is filed in the EUDR Information System, which is free because the Commission bears its costs (Article 18(1) of Implementing Regulation (EU) 2024/3084). Access and roles in the EUDR Information System follow that act as amended by Implementing Regulation (EU) 2026/1565.

Countries: How Does the EUDR Country List Work?

Implementing Regulation (EU) 2025/1093 classes every country as low, standard or high risk.

Which Countries Are High Risk Under the EUDR Country List?

Four countries are high risk: Belarus, North Korea, Myanmar and Russia (Implementing Regulation (EU) 2025/1093, in force since 26 May 2025). The same high-risk country list names 140 low-risk countries; all others are standard risk.

Does Low Risk Mean Simplified Due Diligence and No Geolocation?

No: low risk removes neither geolocation nor the statement (FAQ 1.28). Article 13 drops only Articles 10 and 11, where negligible risk of circumvention or mixing is documented, as explained under simplified due diligence under the EUDR.

Are Brazil and Indonesia High Risk Under the EUDR?

No: Brazil and Indonesia are standard risk, because Implementing Regulation (EU) 2025/1093 does not list them. Standard and high risk carry the same duties, high risk adding enhanced scrutiny (FAQ 6.9); see EUDR and Brazil.

Enforcement: Who Checks, and What Are the Penalties?

National authorities check compliance from 30 December 2026; national laws set penalties (Article 25).

Who Handles EUDR Enforcement, and How Often Are Checks?

National competent authorities, one or more per Member State, handle enforcement (Article 14(1)). Under EUDR enforcement rules, they check yearly at least 1 % (low risk), 3 % (standard) or 9 % plus 9 % of quantity (high) of operators, non-SME downstream operators and non-SME traders (Article 16(8) to (10)).

What Are the EUDR Penalties?

EUDR penalties include fines whose maximum for legal persons must be at least 4 % of total annual Union-wide turnover (Article 25(2)(a)). The catalogue of EUDR penalties adds confiscation, exclusion from procurement for a maximum of 12 months, temporary market bans and a ban on simplified due diligence.

Has Germany Adopted Its EUDR Law?

No: as of 24 October 2026, Germany has no EUDR implementing law in force. The federal government's bill, Bundestag printed paper 21/8278 of 30 September 2026, had its first reading on 8 October 2026, as tracked under EUDR in Germany.

What Does Customs Check Under the EUDR?

Customs check that the reference number or declaration identifier is made available before release for free circulation or export, except for export by a downstream operator (Article 26(4)). Release is not proof of compliance (Article 26(10)), as explained under EUDR at customs.

Every answer is checked against the consolidated text of Regulation (EU) 2023/1115 and the Commission FAQ; see our methodology and fact-checking.

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

How Does This EUDR FAQ Connect to the Guide, Related Frameworks and Tools?

This EUDR FAQ connects each short answer to the page holding the full rule. Those pages form the independent guide to the EU Deforestation Regulation.

Related Frameworks: EUTR, FLEGT and Certification

None of the EUTR, FLEGT licences or certification replaces EUDR due diligence.

What Happens to the EU Timber Regulation (EUTR)?

The EUTR (Regulation (EU) No 995/2010) is repealed from 30 December 2026 but applies until 31 December 2029 to timber produced before 29 June 2023 and placed from 30 December 2026 (Article 37). Transition rules are under EU Timber Regulation (EUTR).

Does a FLEGT Licence Prove EUDR Compliance?

Only for legality: a valid FLEGT licence counts as meeting the legality condition of Article 3(b) (Article 10(3)). Deforestation-free evidence and geolocation remain required; Indonesia and Ghana issue FLEGT licences.

Is There an EUDR Certificate, and What Does Certification Prove?

No: no EUDR certificate exists; the legal output is a reference number or declaration identifier. Certification is complementary information under Article 10(2)(n) (FAQ 5.7), as set out under certification and the EUDR.

Do I Need EUDR Software or a Consultant?

No: the EUDR requires no software, consultant or certification, and the only mandatory IT is the free EUDR Information System. Responsibility stays with the operator (Article 4(3)); platforms are described under EUDR software.