European Deforestation Regulation (EUDR)

Status, September 2026: Postponed a second time in December 2025: large and medium operators and traders apply the EUDR from December 30, 2026, and micro and small operators from June 30, 2027, with simplified due diligence reporting. The Commission published a further simplification package on May 4, 2026. Source: Council of the EU.

What Is the EUDR?

The EU Deforestation Regulation (Regulation 2023/1115), adopted in May 2023, prohibits the placement on the EU market — and export from the EU — of certain commodities and products linked to deforestation or forest degradation. It replaces the weaker EU Timber Regulation and significantly expands the scope of commodities covered and the rigor of due diligence required.

The EUDR reflects the EU's commitment to reducing its global deforestation footprint. The EU is a major consumer of forest-risk commodities, and consumer-driven deforestation is a leading cause of biodiversity loss and greenhouse gas emissions.

Who It Applies To

• Operators: Companies that first place covered products on the EU market or export them. This includes importers, manufacturers, and producers.
• Traders: Companies that make covered products available on the EU market in the course of commercial activity (distributors, retailers).
• Downstream operators and traders: Since the December 2025 amendment (Regulation (EU) 2025/2650), companies further down the supply chain no longer submit their own due diligence statements. They keep records of suppliers, customers, and statement reference numbers for five years, and those that are not SMEs register this information in the EU information system.
• Micro and small primary operators: Can file a one-off simplified declaration instead of full due diligence statements, and may give a postal address instead of geolocation data.

The law applies regardless of where the company is headquartered — what matters is whether the product enters the EU market.

Key Requirements

Due diligence obligation: Companies must exercise due diligence before placing covered products on the EU market:

1. Information collection: Gather geolocation data of the land where the commodity was produced, including GPS coordinates of all plots of land. This is the most novel and challenging requirement.

2. Risk assessment: Assess the risk that the product is linked to deforestation or forest degradation after December 31, 2020. Consider country risk classification (low, standard, high risk — determined by European Commission), complexity of the supply chain, and presence of indigenous peoples and local communities.

3. Risk mitigation: If risk is identified, take adequate measures to mitigate it — this may include independent audits, satellite monitoring, supplier verification, and isotope testing.

Deforestation-free requirement: Products must be produced on land that was not subject to deforestation or forest degradation after December 31, 2020. "Deforestation" means conversion of forest to agricultural use. "Forest degradation" means converting primary or naturally regenerating forests into plantation forests or other wooded land, or converting primary forests into planted forests.

Legality requirement: Products must be produced in accordance with the relevant legislation of the country of production — including land use rights, environmental protection, labor rights, and trade regulations.

Traceability requirement: Full supply chain traceability back to the plot of land where the commodity was produced, with geolocation coordinates.

Covered Commodities and Products

Printed products such as books and newspapers were removed from scope in December 2025. A Commission delegated regulation in force since September 2026 (Delegated Regulation (EU) 2026/2102) removed cattle hides, skins and leather, retreaded tires, soybeans for sowing, and some other items, and adds soluble coffee, frozen cattle tongues, and more palm oil derivatives from December 30, 2027.

Timeline

• June 2023: EUDR entered into force
• December 2024: Originally planned to apply to operators and traders; a first amendment postponed it by 12 months
• May 2025: Commission publishes its country benchmarking (low, standard, high risk)
• December 2025: Second amendment (Regulation (EU) 2025/2650) postpones application again, simplifies obligations, and removes printed products
• May 2026: Commission simplification review finds no further changes to the regulation's text are needed
• September 2026: Delegated Regulation (EU) 2026/2102 updates the product list
• December 30, 2026: Application date for large and medium operators and traders
• June 30, 2027: Application date for micro and small operators
• December 30, 2027: Newly added products, including soluble coffee, come into scope

Compliance Steps

1. Product scope assessment: Identify which of your products fall under EUDR commodity categories
2. Supply chain mapping: Map supply chains back to production origins with geolocation data
3. Due diligence system: Establish or enhance due diligence processes for covered commodities
4. Geolocation data collection: Implement systems to collect GPS coordinates of production plots from suppliers
5. Risk assessment: Evaluate deforestation risk using satellite data, country risk classifications, and supply chain complexity
6. Verification: Verify deforestation-free status using satellite monitoring, field audits, and third-party certification
7. Record-keeping: Maintain due diligence records for 5 years
8. Reporting: Operators placing products on the market for the first time submit due diligence statements through the EU information system (micro and small primary operators can file a one-off simplified declaration)

Penalties

• Fines: Maximum fines must be set at no less than 4% of total annual EU-wide turnover
• Product confiscation: Authorities can seize non-compliant products
• Market exclusion: Temporary prohibition from placing products on the EU market
• Public naming: Publication of non-compliant companies
• Revenue confiscation: Confiscation of revenues from transactions involving non-compliant products

How Council Fire Can Help

Council Fire helps companies navigate EUDR compliance — from supply chain mapping and geolocation data collection through risk assessment systems and due diligence documentation. Contact us for EUDR compliance support.