EU Deforestation Regulation (EUDR): Complete Guide
The EUDR in brief
The EU Deforestation Regulation (EUDR), Regulation (EU) 2023/1115, sets the conditions for placing products made from cattle, cocoa, coffee, oil palm, rubber, soya and wood on the EU market, or exporting them from it. Each product must be deforestation-free, produced under the relevant laws of its country of production and covered by a due diligence statement (Article 3).
The EUDR applies from 30 December 2026. Micro and small operators established by 31 December 2024 have until 30 June 2027, except for timber products already covered by the EU Timber Regulation (EUTR) (Article 38, as amended by Regulation (EU) 2025/2650).
Where do you start?
Am I in scope?
Scope follows the customs codes listed in Annex I of the EUDR. Start with the HS codes on your import or sales documents and check each one against the list.
What must I submit?
The first business to place goods on the EU market, or to export them, files a due diligence statement. Exporters of goods already covered by a due diligence statement do not have to file another (FAQ 5.6.1).
Do I need geolocation?
The due diligence statement needs coordinates for every plot of land that produced the commodity: one point for plots up to four hectares, a polygon for larger plots (Article 2(28)).
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What is the EUDR?
The EUDR is the EU’s law to keep products linked to deforestation off its market. It replaces the EUTR, adds a deforestation test and plot geolocation to the EUTR’s legality test, and covers seven commodities instead of timber alone.
For a business, it comes down to three questions your customer or a competent authority will ask. Where was this grown or harvested? Was the land deforested after 31 December 2020? Was it produced legally? The answer is due diligence: collect the information, assess the risk, resolve any cause for concern, and file a due diligence statement (Articles 4 and 8 to 11). The operator keeps the records for five years and must be able to show how it reached its conclusion (Articles 9 and 10(4)).The EUDR applies from 30 December 2026, and from 30 June 2027 for qualifying micro and small operators.
Which products and commodities are covered?
The seven commodities are cattle, cocoa, coffee, oil palm, rubber, soya and wood (Article 1). The EUDR applies to the products listed by customs code in Annex I that contain, have been fed with or are made from them. These derived products include chocolate, palm oil, plywood, paper, furniture and new tyres. A product not listed in Annex I is out of scope, and so are used and second-hand goods (Annex I, as amended by Delegated Regulation (EU) 2026/2102).
Who does the EUDR apply to?
The operator is the first business to place a product on the EU market, or to export a product that has never been placed on that market. The operator files the due diligence statement. A downstream operator turns goods already covered by a statement into a product with a new customs code; a trader resells such goods unchanged (FAQ 3.1.1). Both keep supplier and customer records for five years, and non-SMEs register in the EUDR Information System. The first business after the operator also receives and keeps the statement’s reference number (Articles 4(7) and 5).
When are the deadlines?
30 December 2026: the EUDR applies (Article 38(2)).30 June 2027: micro and small operators established by 31 December 2024, except for timber products covered by the EUTR (Article 38(3)).31 December 2029: the EUTR stops applying to timber produced before 29 June 2023 (Article 37).
The EUDR due diligence process, step by step
Scoping
List what you buy and sell, with its HS code and the country of production of every component: a wooden chair can draw on three countries. Check each code against Annex I and confirm your role for each product: operator, downstream operator or trader. DX maps what is in scope.
Information collection
Collect the information in Article 9 for each product: description, the species of each wood component, quantity, country of production, suppliers, customers and the geolocation of every plot of land. DX collects and verifies the documents, checks and corrects geolocation files, and analyses the plots for deforestation.
Risk assessment
Test the information against Article 10: the country’s risk classification, deforestation in the area, document falsification and supply chain complexity. Record how you reached the conclusion, because the competent authority will ask to see it (Article 10(4)). Every DX conclusion shows its reasoning, the method and the evidence behind it.
Risk mitigation
Where the assessment leaves any cause for concern, resolve it before the goods move: further documents, supplier engagement or independent surveys (Article 11). Scientific testing is one option where documents cannot settle the question. If a concern remains, the goods cannot be placed on the market (Article 4(4)).
The Due Diligence Statement
When due diligence leaves no cause for concern (negligible risk, Article 2(26)), the operator files the statement in the EUDR Information System before the goods are placed on the market or exported (Article 4(2)). The reference number goes to customs and to the next business in the chain (Articles 4(7) and 26(4)).
EUDR vs EUTR
The EUTR asked timber importers to show legal harvest. The EUDR keeps the legality test and widens it to labour rights, human rights and free, prior and informed consent (Article 2(40)). It adds a test for deforestation and forest degradation after 31 December 2020, plot geolocation, and a due diligence statement filed before the goods move. The EUTR is repealed from 30 December 2026 (Article 37).
EUDR and the Lacey Act
Both ask whether wood was harvested legally. The Lacey Act prohibits importing, buying or selling plants taken in breach of US, state or foreign law, so liability reaches every business that handles the wood, and the goods can be forfeited whatever the importer knew (16 U.S.C. 3372 and 3374). Penalties depend on due care (16 U.S.C. 3373). Under the EUDR, the operator carries responsibility once it files its statement (Article 4(3)).
What happens if you get it wrong
Member States set the penalties. They include fines with a maximum of at least 4% of annual EU-wide turnover, confiscation of the goods and the revenue from them, and exclusion from public procurement for up to 12 months (Article 25). Intentional breaches are also crimes, with a maximum prison term of at least five years (Directive (EU) 2024/1203, Articles 3 and 5). Checks start with your documents, so keep the evidence ready to show.
Your role in the supply chain decides what you do
UK importer. The EUDR does not apply to goods placed on the market in England, Scotland or Wales. Timber placed on the market there falls under the UKTR. Northern Ireland is different: the EUDR applies there in place of the EUTR (Defra guidance, August 2026).
UK supplier to an EU buyer. Your EU customer is the operator and files the due diligence statement. Your customer will ask you for plot coordinates, species, country of production and supplier documents (Article 9), and cannot place the goods on the market without them (Article 4(4)).
Exporter in the US or elsewhere outside the EU. The obligations sit with the business that places the goods on the EU market (Article 2(15)). If you import the goods into the EU in your own name, you are an operator, and the first EU business you sell to is treated as an operator too (Article 7; Commission Guidance, July 2026).
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EUDR frequently asked questions
What is the EUDR in simple terms?
An EU law that lets cattle, cocoa, coffee, oil palm, rubber, soya and wood products onto the EU market, or out of it as exports, only when they are deforestation-free, produced legally and covered by a due diligence statement (Article 3). It applies from 30 December 2026.
What does deforestation-free mean?
Deforestation-free means the commodity was produced on land that has not been converted from forest to farming since 31 December 2020 (Articles 2(3) and 2(13)). Wood has a second test: the harvest must not have degraded the forest after that date, for example by turning natural forest into a plantation (Article 2(7)). Land cleared before the cut-off date does not fail the test, but the product must still be produced legally (Article 3).
Which products does the EUDR cover?
The products listed by customs code in Annex I that contain, have been fed with or are made from the seven commodities. They include timber, plywood, pulp, paper, furniture, charcoal, chocolate, palm oil, soya meal and new tyres. Leather, used and second-hand goods and printed books are out of scope. Soluble coffee and some palm oil derivatives join the list on 30 December 2027 (Delegated Regulation (EU) 2026/2102).
What is a DDS?
A due diligence statement (DDS) is the operator’s declaration that due diligence found no cause for concern, which the EUDR calls negligible risk (Article 4(2)). It is filed in the EUDR Information System before the goods are placed on the EU market, or before they are exported if they have never been placed on that market. It records the operator, HS code, quantity, country of production and the geolocation of every plot of land (Annex II). Each statement receives a reference number.
What is EUDR compliance?
A product meets the EUDR when it is deforestation-free, produced under the relevant laws of its country of production and covered by a due diligence statement (Article 3). A business meets its obligations by doing what its role requires: due diligence and a statement for an operator, records and, for larger businesses, registration for downstream operators and traders (Articles 4 and 5).
What does EUDR stand for?
EU Deforestation Regulation. Its full title is Regulation (EU) 2023/1115 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. Regulation (EU) 2025/2650 amended it in December 2025.
How do you comply with the EUDR?
Confirm your role for each product, then do what that role requires. An operator collects the information in Article 9, including plot geolocation; assesses the risk (Article 10); resolves any cause for concern (Article 11); and files the due diligence statement. Records are kept for five years and the due diligence system is reviewed each year (Article 12). The step-by-step section above covers each stage.
What does negligible risk mean?
It is the standard an operator must reach before goods move. The EUDR defines it as the point where, after a full assessment of the product and its supply chain, and mitigation where needed, there is no cause for concern that the product is not deforestation-free or not legally produced (Article 2(26)). If a concern remains open, the goods stay off the market (Article 4(4)).
Does FSC or PEFC certification meet the EUDR?
Not on its own. Certification can support a risk assessment to the extent it covers the information the EUDR requires, but the operator still carries out due diligence and remains responsible (Commission FAQ 5.7). Certified material still needs plot geolocation and a due diligence statement.
Sources and references
Article references on this page are to Regulation (EU) 2023/1115 as amended by Regulation (EU) 2025/2650 of 19 December 2025, with Annex I as amended by Commission Delegated Regulation (EU) 2026/2102.
- European Commission, Guidance document for Regulation (EU) 2023/1115 (OJ C, 20 July 2026).
- European Commission, Frequently Asked Questions on the EUDR, version 5 (April 2026).
- Directive (EU) 2024/1203 on the protection of the environment through criminal law.
- Department for Environment, Food and Rural Affairs, Moving, exporting or placing deforestation-free products on the market in Northern Ireland (GOV.UK, updated 27 August 2026).
- Lacey Act: 16 U.S.C. 3372, 3373 and 3374.
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