EUDR Guidance
EUDR Guidance: The Commission Guidance Document, FAQ, Implementing and Delegated Acts
EUDR guidance document C/2026/3896, FAQ Version 5 and the implementing and delegated acts of Regulation (EU) 2023/1115: what each settles, how binding.
Summary
The Commission explains Regulation (EU) 2023/1115 in Guidance Document C/2026/3896 (third edition, OJ C of 20 July 2026) and FAQ Version 5 (April 2026), and implements it through three implementing regulations and one delegated regulation.
The guidance and the FAQ are non-binding explanations under Article 15(5); the Regulation and the four acts adopted under it are law. The delegated act, Delegated Regulation (EU) 2026/2102 of 13 July 2026, changes the CN codes of Annex I, while the implementing acts run the EUDR Information System and classify countries by risk.
The EU Deforestation Regulation itself, in force since 29 June 2023 (Article 38(1)), governs seven commodities (cattle, cocoa, coffee, oil palm, rubber, soya and wood) and the products made from them. Its official instruments differ in issuer, legal basis and weight, and Table 1 registers each one with its position on 5 November 2026.
Table 1. The EUDR instruments register
| # | Instrument | Type and legal weight | What it settles | Position on 5 November 2026 | Covered on |
|---|---|---|---|---|---|
| 1 | Guidance Document C/2026/3896 | Commission Notice, non-binding | Interpretation in 11 chapters | Current third edition | This page |
| 2 | FAQ Version 5 | Commission, non-binding | Worked examples, system questions | April 2026; page dated 2026-08-21 | EUDR FAQ |
| 3 | Implementing Regulation (EU) 2024/3084, as amended by 2026/1565 | Binding (Art. 33(3)) | Information system, 72-hour amendment window, contingency, costs | Consolidated 2026-10-15 | EUDR Information System |
| 4 | Implementing Regulation (EU) 2025/1093 | Binding (Art. 29(2)) | 140 low-risk, 4 high-risk countries, all others standard | Not amended | Implementing Regulation 2025/1093 |
| 5 | Delegated Regulation (EU) 2026/2102 | Binding (Art. 34(1)) | Annex I removals from 2026-09-18; 18 added entries from 2027-12-30 | In force; Czech corrigendum 2026-10-22 | delegated act amending EUDR Annex I |
| 6 | Other Commission documents | Non-binding | See Table 5 | See Table 5 | See Table 5 |
The guidance and FAQ explain but do not change the EUDR (Article 15(5)).
What Are the EUDR Guidelines and Who Issues Them?
The EUDR guidelines are the Commission's guidance document under Article 15(5), now Commission Notice C/2026/3896 of 20 July 2026, which "does not replace, add to or amend the provisions of the EUDR". Article 15(5) of Regulation (EU) 2023/1115 allows the Commission to facilitate harmonised implementation "by issuing relevant guidelines" and by collecting technical feedback from its Multi-Stakeholder Platform on Protecting and Restoring the World's Forests.
The issuer is the European Commission; its Directorate-General for Environment manages the EUDR implementation pages. The notice states that its issues "were discussed and developed in cooperation with designated representatives of the Member States", and that it "can guide operators and traders".
Guidance Document C/2026/3896 Chapter by Chapter: Roles, Dates, Due Diligence, Legality, Product Scope, Certification and Forest Definitions
The third edition has 11 chapters, from the definitions of placing on the market to agricultural use, each interpreting named articles. Table 3 gives every chapter with its key positions and the page that covers it in depth.
Table 3. The 11 chapters of Guidance Document C/2026/3896
| Chapter | Topic | Key positions (section) | Covered in depth on |
|---|---|---|---|
| 1 | Placing on the market, making available, export | Importer in data element 13 04 000 000 generally the operator at import; freight forwarders, shipping agents and customs representatives without ownership are neither operators nor traders (s. 1) | This page |
| 2 | Operator, micro or small primary operator, downstream operator, trader | Roles under Art. 2(15), (15a), (15b) and (17) as amended by Regulation (EU) 2025/2650 (s. 2) | EUDR roles |
| 3 | Date of effect and time-frame for application | Production date = harvest date, for cattle the birth date; products produced before 2023-06-29 outside the EUDR (s. 3) | EUDR dates in force |
| 4 | Due diligence, points (a) to (f) | Risk assessed per source or geolocation (s. 4(a)); micro or small primary operators "by definition" source from a low-risk country (s. 4(c)) | EUDR due diligence |
| 5 | Complexity of the supply chain | Checklist of complexity factors (s. 5) | This page |
| 6 | Legality | Only laws on the legal status of the area of production; no land title where domestic law requires none (s. 6) | EUDR legality requirement |
| 7 | Product scope | 4819 and 4415 in scope as products in their own right, not when supporting, protecting or carrying another product; sawdust in scope (4401); used coffee grounds out (s. 7) | EUDR product scope |
| 8 | Regular maintenance of a due diligence system | Keeping the system up to date (s. 8) | This page |
| 9 | Composite products | Commodity linked to the Annex I heading (s. 9) | This page |
| 10 | Certifications and third-party verification schemes | Schemes inform risk assessment and mitigation (s. 10) | certification and the EUDR |
| 11 | Agricultural use | Agroforestry land "cannot be considered as 'forest'" (s. 11.4(d)); plantations with rubber or oil palm trees are not forest (s. 11.4(c)); land abandoned generally more than 10 years with regenerated forest is forest (s. 11.3) | forest definition under the EUDR |
Chapter topics follow the notice; every position is the Commission's non-binding view.
Simplified due diligence under section 4(e) keeps Articles 8, 9 and 12 but drops the risk assessment and mitigation of Articles 10 and 11, after the operator has assessed supply-chain complexity and the risk of mixing. Section 9 limits due diligence on composite products to the commodity linked to the Annex I heading: a chocolate bar under 1806 needs due diligence on cocoa, not on the palm oil it contains. Footnote 18 adds that mixed products from mass balance chains of custody are "not compliant with the EUDR".
Section 4(f) explains the interplay of the EUDR with the Corporate Sustainability Due Diligence Directive and the Forced Labour Regulation.
Which Earlier Guidance Editions Are Superseded?
Two earlier editions are superseded: C/2024/6789 of 13 November 2024 and C/2025/4524 of 12 August 2025, which recital 11 of Regulation (EU) 2025/2650 cites. Each edition received a corrigendum (Table 2). The second edition of August 2025 predates Regulation (EU) 2025/2650, in force since 26 December 2025.
Table 2. Guidance document editions
| Edition | Reference and CELEX | OJ C | Corrigendum | Position |
|---|---|---|---|---|
| First | C/2024/6789, 52024XC06789 | 2024-11-13 | 2025-09-09 | Superseded |
| Second | C/2025/4524, 52025XC04524 | 2025-08-12 | 2025-09-22 | Superseded |
| Third | C/2026/3896, 52026XC03896 | 2026-07-20 | 2026-08-07 (Bulgarian, Finnish, Irish, Dutch) | Current |
The third edition replaces the second by edition sequence; the notice does not state the repeal expressly.
Where Does the Third Edition Differ From the Regulation Text?
In two places the third edition reads differently from the act or leaves a value open, listed below.
- Postal address reference. Section 4(c) lets micro or small primary operators use a postal address "instead of geolocation required by Article 9(1)(h)", while Article 4a(5), inserted by Regulation (EU) 2025/2650, refers to "the geolocation referred to in Article 9(1), point (d)". Article 4a(5) is the provision to cite.
- Set-aside period. Section 11.4(a) keeps set-aside or fallow land under agricultural use "generally for [ten] years", brackets as printed in the English text. The corrigendum of 7 August 2026 concerns the Bulgarian, Finnish, Irish and Dutch versions only.
In both cases the binding wording is the consolidated Regulation of 18 September 2026.
How Binding Is Each Instrument Compared With Regulation (EU) 2023/1115?
Only Regulation (EU) 2023/1115 and the acts adopted under it bind operators and authorities; the guidance document and the FAQ are non-binding explanations (Article 15(5)). The Regulation (OJ L 150, 9.6.2023, p. 206) is binding in its entirety and directly applicable in every Member State. Its consolidated version of 18 September 2026 remains the latest on 5 November 2026, and every article and annex of Regulation (EU) 2023/1115 is explained in that version.
Table 4. Legal weight of the EUDR instruments
| Type | Instruments | Basis | How adopted | Binding? | What it can change |
|---|---|---|---|---|---|
| Regulation | 2023/1115, 2024/3234, 2025/2650 | Treaty | Parliament and Council | Yes, directly applicable | Everything |
| Delegated regulation | 2026/2102 | Art. 34(1), Art. 35 | Commission; no objection within 2 months, extendable by 2 (Art. 35(6)) | Yes | Annex I CN codes only |
| Implementing regulations | 2024/3084, 2026/1565, 2025/1093 | Art. 33(3), Art. 29(2) | Examination procedure (Art. 36(2)) | Yes | Rules for application, never the act |
| Guidance | C/2026/3896 | Art. 15(5) | Commission Notice | No | Nothing |
| FAQ | Version 5 | Art. 15(5) | Commission | No | Nothing |
| Other documents | Table 5 | Art. 15(5), Art. 30 | Commission | No | Nothing |
The delegated act has the narrowest power: Article 34(1) lets the Commission amend Annex I only "with regard to the relevant CN codes of relevant products". Under Article 35(6), a delegated act enters into force only if neither Parliament nor Council objects within two months of notification, a period extendable by two months at their initiative. Implementing acts follow the examination procedure of Article 5 of Regulation (EU) No 182/2011 (Article 36(2)) and lay down rules for applying the EUDR without amending it.
Footnote 1 of the guidance notice states: "Only the European Court of Justice can make final judgments on the Regulation's interpretation." The same notice "can also guide national competent authorities and enforcement bodies as well as national courts".
Which Implementing Regulations Apply Under the EUDR?
Three implementing regulations apply under the EUDR: 2024/3084 on the information system, its amending act 2026/1565 and 2025/1093 on country risk. None of them amends Regulation (EU) 2023/1115.
Implementing Regulation (EU) 2024/3084, as Amended by 2026/1565: Information System Rules
Implementing Regulation (EU) 2024/3084 of 4 December 2024, in force since 9 December 2024, sets the rules for the functioning of the EUDR Information System (basis Article 33(3)). Its Article 1, as replaced, covers personal data protection, data exchange with other IT systems and contingency arrangements. A due diligence statement can be amended or withdrawn within 72 hours after the reference number is made available (Article 5(1)), and the Commission bears the set-up, maintenance and operation costs (Article 18(1)).
Implementing Regulation (EU) 2026/1565 of 13 July 2026 (OJ L, 14.7.2026) has amended it since 17 July 2026. From 15 October 2026, its Article 1(2)(c) attributes each statement to the competent authority of the Member State of establishment. The amending act deletes the reference to TRACES (recital 6) and adds Article 15a: a public website by 30 December 2026 on contingency measures for unplanned unavailability exceeding 60 minutes.
Implementing Regulation (EU) 2025/1093: Classifying Countries by Risk
Implementing Regulation (EU) 2025/1093 of 22 May 2025, in force since 26 May 2025, lists 140 low-risk and 4 high-risk countries; every other country is standard risk. The four high-risk countries are Belarus, North Korea, Myanmar and Russia, and the act rests on Article 29(2). The class rates deforestation risk under Article 3(a) only.
The guidance reads the list the same way. Footnote 9 states that "if no specific risk level has been assigned, countries are considered standard risk", and footnote 11 calls Implementing Regulation (EU) 2025/1093 the "latest iteration of the list of countries".
What Does the Commission FAQ Add to the Guidance Document?
The Commission FAQ is a separate, non-binding question-and-answer document: Version 5 of April 2026, published on the Commission page on 21 August 2026 and still current on 5 November 2026. Titled "Implementation of the EU Deforestation Regulation - Frequently Asked Questions", it runs to 95 pages in 10 sections, from traceability (section 1) to penalties (section 10), and replaces the fourth iteration of April 2025.
Three statements in circulation are outdated, listed below.
- Annex I act: FAQ Version 5 (April 2026), 2.7, 2.8.1, 2.13 and 2.14 call the Annex I act a draft; it was adopted as Delegated Regulation (EU) 2026/2102.
- Information system act: the FAQ describes Implementing Regulation (EU) 2024/3084 as under amendment; Implementing Regulation (EU) 2026/1565 has amended it.
- Older copies: an older English FAQ hosted by the German Bundesanstalt für Landwirtschaft und Ernährung (BLE) lists slaughterhouses among establishments, ties the production date of cattle products to slaughtering and uses a "cars with leather seats" example.
Against that older copy, the production date of cattle is now the birth date (Guidance, section 3), and leather has been outside Annex I since 18 September 2026.
Which Other Commission Documents Cover Traceability, Producer-Country Legislation and Cooperation?
Four further Commission documents and tools support the guidance; none of them is binding. Table 5 dates each one; the repositories of producer-country legislation and of certification schemes are still "under construction" on the Commission's Green Forum page on 5 November 2026.
Table 5. Other Commission documents and tools
| Document | Reference and date | What it does | Position on 5 November 2026 | Covered on |
|---|---|---|---|---|
| Strategic Framework for International Cooperation Engagement | C/2024/6604, OJ C 2024-11-07 | Cooperation with producer countries (Art. 30) | Published | This page |
| Supply Chain Infographics | Commission, Green Forum | Roles of operators, downstream operators, traders and micro or small primary operators at each supply-chain stage | 5th edition, released 2026-09-03 (Publications Office) | EUDR traceability |
| Multi-Stakeholder Platform | Commission expert group named in Art. 15(5) | Technical feedback; meeting summaries on the Green Forum | 89 members: 62 stakeholders, 27 Member States (COM(2026) 191, s. 3) | This page |
| Legislation and certification-scheme repositories | International Trade Centre with the Commission | Producer-country legislation (Art. 2(40)) and scheme information | Under construction; Guidance, section 6 plans the legislation repository by December 2026 | This page |
Do the Guidance and the Implementing Acts Require Software, Consultants or Certificates?
No: none of the instruments requires software, a consultant or a certificate; the only mandatory system is the EUDR Information System, free of charge to its users (Implementing Regulation (EU) 2024/3084, Article 18(1)). No EUDR software or provider holds an approved status, and responsibility stays with the operator (Articles 4(3) and 6(1)). What compliance platforms do is described under EUDR software.
No EUDR certificate exists either. The legal output is the DDS reference number or the declaration identifier of a simplified declaration. Certification counts as information for the risk assessment under Article 10(2)(n) and supports but does not replace due diligence (FAQ 5.7). Guidance, section 10 adds that scheme assurances "should not be relied upon in isolation or taken as conclusive".
Which Instruments Are New, Corrected or Proposed as of 5 November 2026?
As of 5 November 2026, no implementing or delegated act has been added since the two acts of 13 July 2026, and the guidance and FAQ editions are unchanged.
Table 6. Position of each instrument on 5 November 2026
| Instrument | Position | Checked at |
|---|---|---|
| Regulation (EU) 2023/1115 | Consolidated version 02023R1115-20260918 is the latest | Publications Office (Cellar) |
| Guidance C/2026/3896 | Third edition; corrigendum of 2026-08-07 only | Publications Office (Cellar) |
| FAQ | Version 5; page dated 2026-08-21 | Commission FAQ page |
| Implementing Regulation (EU) 2024/3084 | Consolidated version of 2026-10-15 is the latest | Publications Office (Cellar) |
| Implementing Regulation (EU) 2025/1093 | Not amended | Publications Office (Cellar) |
| Delegated Regulation (EU) 2026/2102 | In force since 2026-09-18; Czech corrigendum of 2026-10-22 | Publications Office (Cellar) |
| New implementing or delegated acts since 2026-07-20 | None | Publications Office (Cellar) |
| COM(2026) 661 | Proposed 2026-09-10; preparatory phase in Parliament | Legislative Observatory (2026/0261(CNS)) |
COM(2026) 661 proposes, under Article 349 TFEU, to exclude French Guiana from the territorial scope of the EUDR; it remains a proposal. The French Guiana proposal is followed with the other territorial rules.
Every instrument on this page is checked against EUR-Lex and Commission sources; see how EUDR Guide verifies every fact. Placement on EUDR Guide is never sold.
This guide explains the rules; it is not legal advice for an individual case.
How Does EUDR Guidance Connect to Postponements and the 2026 Commission Review?
The guidance follows the dates set by the amending regulations and was updated after the Commission's simplification review.
Is Another Postponement Proposed?
No: as of 5 November 2026 no proposal to postpone the EUDR again exists. The main obligations apply from 30 December 2026 (Article 38(2)), and each earlier EUDR postponement is documented with the act that decided it.
What Did the 2026 Commission Review Change for the Guidance?
COM(2026) 191 of 4 May 2026 announced an updated guidance and FAQ and the two repositories, and proposed no amendment. The report, required by Article 34(1a), also announced the Annex I delegated act; its findings are set out under the 2026 Commission review.
What Else Do Readers Ask About the Guidance Document?
Readers also ask where the official text of Guidance C/2026/3896 sits and in which languages it exists.
Where Is the Official Guidance PDF?
The reference text is the OJ C publication on EUR-Lex (ELI http://data.europa.eu/eli/C/2026/3896/oj); the Commission also links the guidance as a PDF ("Read the Guidance") from its Green Forum page on implementing the EUDR.
Is the Guidance Available in Every EU Language?
Yes: since 13 July 2026 the guidance, previously only in English, is formally adopted in all EU languages, according to the Commission's announcement of that date. FAQ Version 5 is also published in all EU languages.
Sources
- EUR-Lex: Regulation (EU) 2023/1115
- EUR-Lex: CELEX 02023R1115
- EUR-Lex: eur-lex.europa.eu/eli/C/2026/3896/oj/eng
- EUR-Lex: eur-lex.europa.eu/eli/C/2025/4524/oj/eng
- EUR-Lex: eur-lex.europa.eu/eli/C/2024/6789/oj/eng
- European Commission, Environment: environment.ec.europa.eu/publications/faq-eudr-implementation_en
- European Commission, Environment: environment.ec.europa.eu/news/…
- European Commission, Green Forum: green-forum.ec.europa.eu/nature-and-biodiversity/deforestation-regulation-implementation_en
- EUR-Lex: CELEX 02024R3084
- EUR-Lex: Implementing Regulation (EU) 2026/1565
- EUR-Lex: Implementing Regulation (EU) 2025/1093
- EUR-Lex: Delegated Regulation (EU) 2026/2102
- EUR-Lex: CELEX 52024XC0660
- EUR-Lex: CELEX 52026DC0191
- European Parliament: oeil.europarl.europa.eu/oeil/en/procedure-file?reference=2026/0261(CNS)
- ble.de: ble.de/SharedDocs/Downloads/EN/Entwaldungsfrei/…