EUDR: A practical guide to deforestation regulation compliance

Last Updated: January 20, 2026

The EUDR deforestation regulation (Regulation (EU) 2023/1115) (also called the EU deforestation law) represents one of the most significant shifts in environmental trade policy in a generation. For any business trading in cattle, cocoa, coffee, oil palm, rubber, soya, or wood and their derived products, understanding EUDR compliance is a mandatory condition for accessing the European Union market.

A vital note for UK businesses:

While the UK is no longer an EU Member State, the EUDR applies directly to any legal or natural person (including those based in the UK) who places relevant products on the EU market. There is currently no equivalent UK-wide regulation covering all seven commodities, meaning UK companies exporting these goods to the EU must comply fully with the EUDR. This cross-border complexity is a key area where we provide essential support.

Understanding the EUDR deforestation regulation

The EUDR, or Regulation on Deforestation-Free Products, entered into force on 29 June 2023. Its core objective is to minimise the EU’s contribution to global deforestation and forest degradation. It does this by prohibiting the placement on the EU market, or the export from it, of specific commodities and products unless they are proven to be deforestation-free, legally produced, and covered by a due diligence statement.

This regulation repeals and significantly expands the previous EU Timber Regulation (EUTR). It moves from a focus on the legality of timber to a stricter requirement for deforestation-free sourcing for 7 commodity groups, with robust supply chain due diligence obligations for the companies that place these goods on the market.

Does the EUDR apply to your business? A three-point test

You can determine if the EUDR applies to your operations by answering three sequential questions.

1

Is your product listed in EUDR Annex I (e.g., cattle, cocoa, coffee, oil palm, rubber, soya, wood, or derived products like leather, chocolate, furniture)?

No → The EUDR does not apply.
Yes → Proceed to question 2.
2

Is your commercial activity ‘placing on’, ‘making available on’, or ‘exporting from’ the EU market?

No → The EUDR does not apply.
Yes → Proceed to question 3.
3

Was the product produced (e.g., harvested, reared) on or after 29 June 2023?

No → The EUDR likely does not apply.
Yes → Your business is subject to the EUDR.

Note: Printed books, newspapers, and similar printed matter have been removed from the product scope under the new amended regulation.

The three pillars of EUDR compliance

For a relevant product to legally enter or leave the EU market, it must satisfy all three of these non-negotiable conditions simultaneously:

1. Deforestation-free:

The product must be deforestation-free. This means the relevant commodities were produced on land that has not been subject to deforestation (conversion of forest to agricultural use) or forest degradation after 31 December 2020.

Location requirement: To prove this, operators must obtain information on the origin. For standard operators, this is the geographical coordinates (geolocation) of every plot of land. For micro or small primary operators (see below), a postal address of the plot or establishment may suffice.
No mixing: If a single ingredient in a batch comes from a plot deforested after the cut-off date, the entire batch is non-compliant. Mixing compliant and non-compliant or unknown materials is prohibited.

2. Legal compliance:

The product must have been produced in accordance with the relevant legislation of the country of production. This is broader than just forestry laws and covers the legal status of the production area, including:

Land use rights and environmental protection.
Labour rights and human rights protected under international law.
The principle of Free, Prior and Informed Consent (FPIC) for indigenous peoples.
Tax, anti-corruption, trade, and customs regulations.

3. Due diligence statement:

The product must be covered by either a Due Diligence Statement (DDS) submitted by a standard operator or a simplified declaration identifier from a micro/small primary operator. This electronic record is entered into the official EU Information System, declaring that the due diligence obligations have been met.

Operator vs. trader obligations

Your specific duties under the EUDR depend on your role in the supply chain and your company size.

Role	Definition	Obligations
Operator	The entity (not downstream/micro/small primary) that first places a relevant product on the EU market or exports it (e.g., an importer, a domestic manufacturer creating a new relevant product).	Must establish a full due diligence system, conduct due diligence for each product/supplier, and submit a DDS before placing/exporting.
Micro or small primary operator	A natural person or micro/small undertaking in a low-risk country who places/exports products they produced themselves.	Exempt from regular DDS. Must submit a one-time simplified declaration in the Information System to receive a Declaration Identifier that accompanies their products. Can use a postal address instead of geolocation coordinates. May be exempt if data is in official databases.
Downstream Operator	An entity placing on the market/exporting relevant products made using relevant products already covered by a DDS or simplified declaration.	No longer required to submit new DDS. Must collect and keep information on suppliers/customers and the DDS reference numbers or declaration identifiers for 5 years. This duty applies only to the first downstream actor in a chain.
Non-SME trader	A large company (not an operator) that makes available relevant products already placed on the market (downstream in the supply chain).	Treated as an operator. Must register in the Information System but does not submit DDS; must pass on reference numbers/identifiers.
SME trader	A micro, small, or medium-sized enterprise making products available downstream.	Exempt from due diligence and DDS submission. Must keep records of suppliers, customers, and DDS reference numbers for 5 years.

SME operator simplification condition: SME operators placing products on the market are exempt from conducting new due diligence and submitting a new DDS if the product is made from components that have already been subject to due diligence with a DDS submitted upstream. They must only keep the reference number.

Under the new rules, the Upstream Operator creates the main compliance proof (DDS). Downstream actors (operators and traders) are primarily “information carriers” who ensure this proof is not lost as the product moves through the supply chain, eliminating the need for repetitive new submissions at each step.

Example: A UK-based SME furniture maker imports due-diligenced sawn wood (with a DDS) and manufactures chairs. As the wood already has a DDS, the SME does not need to submit a new one for the chairs, but retains the wood’s DDS reference and responsibility for the final product’s compliance.

For further guidance tailored to your specific operations, our regulatory experts are available to assist:

Building your due diligence system step-by-step

For upstream operators, compliance hinges on establishing a documented Due Diligence System (DDS). This is not a one-off check but an ongoing management process. The system comprises three steps:

Step 1: Information collection

You must collect, organise, and keep for five years specific information for each product and supplier. Crucially, this includes:

Product description and quantity.
Country of production and geolocation of all plots of land (or postal address for eligible small primary operators).
Adequately conclusive and verifiable information that the product is deforestation-free and legally produced (e.g., land titles, audit reports, verifiable supplier declarations).
Names and addresses of your suppliers and buyers.

Practical insight: Collecting geolocation from smallholders may involve using simple GPS data from mobile phones. Your due diligence must include procedures to verify this data, for instance by cross-checking with satellite imagery.

Step 2: Risk assessment

You must analyse the collected information to assess if there is more than a negligible risk the product is non-compliant. You must consider criteria including:

The country benchmarking classification (Low, Standard, or High risk) of the production area.
The complexity of your supply chain (number of intermediaries, processing stages).
Prevalence of corruption, illegal practices, or human rights issues in the region.
Information from certification schemes (e.g., FSC, RSPO).

Important: Certification can support your assessment but does not replace your due diligence obligation. Many schemes have rules (like mass balance mixing) that are not compliant with the EUDR’s strict traceability rules.

Hypothetical case: A Belgian chocolate manufacturer (now a downstream operator) sources cocoa paste from a cooperative that has a valid DDS. They no longer need to submit a new DDS for their chocolate. Their duty is to keep the cocoa paste’s DDS reference number and collect their customer’s details.

Step 3: Risk mitigation

If the assessment shows a non-negligible risk, you must take measures to reduce it to negligible before proceeding. Measures can include:

Requiring additional information or documents from suppliers.
Conducting independent audits or field visits.
Supporting suppliers to improve their practices.
For non-SME upstream operators, appointing a compliance officer and establishing an internal audit function.

Your entire Due Diligence System must be reviewed and updated at least annually, and for non-SME operators, a public report on the system is required.

Managing complex real-world scenarios

Composite products:

Many products contain multiple relevant commodities (e.g., chocolate containing cocoa and palm oil). If you are an upstream operator, your obligation is to conduct due diligence on the components linked to the main commodity of the final product’s HS code. If a component already has a DDS, you can reference it. If it doesn’t, you must perform full due diligence for that part. If you are a downstream operator using already due-diligenced components, you simply keep the associated reference numbers.

Waste and recycled materials:

Products made entirely from recycled material (e.g., paper from 100% recycled pulp) are excluded. However, if a product contains any virgin or non-recycled relevant material (e.g., new leather in a refurbished bag), that portion is fully in scope.

The Authorised Representative as a solution:

Operators, especially those outside the EU, can mandate an Authorised Representative established in the EU to submit the DDS on their behalf. This is a helpful service for ensuring formal compliance. However, the mandating operator retains full legal responsibility for the product’s compliance.

The compliance machinery: tools, checks, and penalties

The EU Information System

The online portal for operator registration and DDS submission. It became operational in December 2024. To access the Information System, please use this link.

To help you get familiar with the system, a replica training platform, called ACCEPTANCE Server is available. To access the ACCEPTANCE system please use this link.

Note: 24hour-AR is a validated operator under the EUDR Information System and is ready for DDS submissions as an AR.

Example authorised representative 24hour-AR

Country benchmarking: The European Commission classified countries as Low, Standard, or High risk. Sourcing from Low-risk countries may allow simplified due diligence.

Key EUDR deadlines: Core obligations apply from 30 December 2026 for large/medium enterprises. Micro and small enterprises benefit from a deferred date of 30 June 2027. The EUTR will be fully repealed by 31 December 2029.

Enforcement and penalties

EU Member State competent authorities will perform checks based on a risk-based approach. They are mandated to check at least 9% of operators dealing with high-risk country products. Checks can be unannounced and may involve document reviews, site visits, and even audits in third countries.

Penalties for non-compliance are severe and designed to be dissuasive, including:
– Fines proportionate to environmental damage, potentially up to 4% of the company’s annual EU-wide turnover.
– Confiscation of products and revenues from the transaction.
– Temporary exclusion from public procurement.
– Public naming of companies found in breach.

Your path from understanding to action

The EUDR mandates a proactive, systematic approach to supply chain management and transparency. For upstream operators, the time to act is now.

1

Map your supply chain and role: Identify all relevant products you place or make available on the EU market against Annex I. Determine your role (Upstream Operator, Micro/Small Primary, Downstream Operator, Trader) and size status.
2

Engage with suppliers: Initiate conversations to gather mandatory information. Understand if your suppliers qualify as micro/small primary operators.
3

Draft your framework: If you are an upstream operator, begin documenting the policies, controls, and procedures that will form your Due Diligence System.
4

Consider expert guidance: The nuances of the new roles, the complexity of geolocation verification, legal analysis across multiple jurisdictions, and system setup is substantial. A professional consultant can provide clarity, mitigate risk, and ensure a robust, efficient path to compliance.

The EUDR is a formidable regulation, but with structured preparation, compliance is an achievable and necessary commercial goal.

For a confidential discussion on your company’s specific obligations and a tailored approach to achieving compliance, please contact our specialist team.

Conclusion

The EUDR represents a fundamental shift in how the EU regulates commodities linked to deforestation. Whether you’re an upstream operator with full due diligence duties or a downstream actor managing DDS reference numbers, the regulation requires systematic preparation and end-to-end supply chain transparency.

With penalties of up to 4% of annual EU turnover and core obligations applying from 30 December 2026, early action is essential. Success depends on correct role classification, strong supplier engagement, and reliable geolocation verification—areas where expert support can turn regulatory complexity into practical, auditable compliance.

If you’re unsure about your EUDR obligations or need help with DDS submissions, our team is ready to support you in securing compliant EU market access.

Author Ferry Vermeulen is the Co-Founder of 24hour-AR, a company dedicated to providing authorised representative services as well as CE marking services. With a background in industrial design engineering, Ferry specialises in facilitating swift compliance with EU regulations, enabling manufacturers to enter markets seamlessly.

Frequently asked questions

What does EUDR stand for, and what is its purpose?2025-12-30T20:35:36+00:00

What does EUDR stand for, and what is its purpose?

EUDR stands for the EU Regulation on Deforestation-Free Products (Regulation (EU) 2023/1115). Its purpose is to minimise the EU’s contribution to global deforestation and forest degradation by ensuring products sold in or exported from the EU are not linked to recent deforestation and are legally produced.

Does the EUDR apply to my business?2025-12-30T20:37:17+00:00

Does the EUDR apply to my business?

It applies if you place on, make available on, or export from the EU market any of the seven relevant commodities (cattle, cocoa, coffee, oil palm, rubber, soya, wood) or their derived products listed in Annex I, and those products were produced after 29 June 2023. Timber and timber products are subject to specific transitional rules where they were harvested before that date.

What products are covered by the EUDR?2025-12-30T20:37:55+00:00

What products are covered by the EUDR?

Covered products are listed in EUDR Annex 1. This includes raw commodities and a wide range of derived products like leather, chocolate, furniture, tyres, printed paper, and many more. You must check the official annex against your product’s Harmonised System code.

Who is affected by the EUDR (Operator vs. Trader, SME vs. Non-SME)?2025-12-30T20:38:46+00:00

Who is affected by the EUDR (Operator vs. Trader, SME vs. Non-SME)?

New categories define obligations. Upstream Operators have the fullest duties. Micro/Small Primary Operators (own-production in low-risk countries) have simplified declarations. Downstream Operators and Non-SME Traders no longer submit DDS but must keep reference numbers. SME Traders have light record-keeping duties.

What are the key requirements for EUDR compliance?2025-12-30T20:38:32+00:00

What are the key requirements for EUDR compliance?

Three cumulative conditions: 1) Products must be deforestation-free (no deforestation after 31/12/2020), 2) produced in accordance with local legislation, and 3) covered by a Due Diligence Statement or a simplified declaration identifier.

What is the difference between the EU Timber Regulation (EUTR) and the EUDR?2025-12-30T20:39:06+00:00

What is the difference between the EU Timber Regulation (EUTR) and the EUDR?

The EUTR focused only on the legality of timber. The EUDR covers seven commodities, requires them to be deforestation-free (not just legal), and imposes stricter due diligence with mandatory geolocation traceability. The EUTR will be fully repealed by the end of 2029.

What is the difference between EUDR and FSC/certification schemes?2025-12-30T20:39:27+00:00

What is the difference between EUDR and FSC/certification schemes?

FSC is a voluntary certification scheme for sustainable forestry. The EUDR is a mandatory law. FSC certification can be used as supporting evidence in your EUDR risk assessment, but it does not automatically guarantee EUDR compliance, as the EUDR has unique requirements (like the 2020 cut-off date and strict chain-of-custody rules).

Has the EUDR been delayed, and what are the key deadlines?2025-12-30T20:39:45+00:00

Has the EUDR been delayed, and what are the key deadlines?

The main application date was postponed. Core obligations now apply from 30 December 2026 for large and medium enterprises. Micro and small enterprises have a later application date of 30 June 2027.

How can companies prepare for and achieve EUDR compliance?2025-12-30T20:40:03+00:00

How can companies prepare for and achieve EUDR compliance?

Start by mapping your supply chain against Annex I. Then, identify your role and begin engaging suppliers to collect required information. Develop the framework for your three-step due diligence system. Consider seeking expert guidance to navigate the complexities.

What are the penalties for non-compliance with the EUDR?2025-12-30T20:40:18+00:00

What are the penalties for non-compliance with the EUDR?

Penalties are severe and include fines (up to 4% of EU turnover), confiscation of products and revenues, exclusion from public contracts, and public naming of offending companies.

Q&A section

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