The EU Deforestation Regulation (EUDR) is a law designed to ensure that certain commodities placed on or exported from the EU market are deforestation-free. This means that companies must ensure their products are not linked to deforestation or forest degradation. In late 2025, the European Parliament, Council, and Commission formally approved a 12-month delay and a series of simplifications.

The new application dates are:

• 30 December 2026 for large and medium operators
• 30 June 2027 for small and micro operators (for non-timber products)

EUDR applies to cattle, wood, cocoa, coffee, palm oil, soy, and rubber, including derived products. To comply, companies must trace their supply chains, assess risks, mitigate issues, and submit official due diligence statements. This article provides a comprehensive seven-step guide for business users to comply with EUDR.

Complying with EUDR in 2026: What companies need to know

The revised EUDR enforcement dates and role simplifications have now been approved and are expected to become legally binding once published in the Official Journal. That means companies should start adjusting their plans based on the updated rules.

Here's what to focus on in 2026:

• Operators still need to prepare. If you place or export in-scope products, the due diligence process remains mandatory. This guide walks through all required steps. For a broader overview of supply chain due diligence as a practice, see our supply chain due diligence guide.
• New roles change what's required. Small and micro primary operators will soon file a one-time declaration instead of full due diligence. Downstream operators no longer submit DDSs but must maintain traceability by passing on DDS references.
• Simplifications don't mean inaction. Even with reduced obligations, companies must still ensure traceability, legality, and deforestation-free sourcing.

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Step 1: Confirm your role (operator, trader) in the EUDR process

The obligations of companies under EUDR are based on their role in the value chain and their size. Determining your role is the first step in compliance.

Are you an operator or a trader?

Your first task is to determine whether your company is considered an operator or a trader, as obligations differ.

Operator

Places in-scope products on the EU market for the first time in the product's value chain, or exports them.

Trader

Buys and resells in-scope products already on the EU market without transforming them.

Updated EUDR roles and responsibilities following Parliament vote

To simplify implementation, the Parliament approved (26 November) the introduction of two new categories:

Downstream operators: entities that process or sell already EUDR-compliant products. They now: do not have to submit a new Due Diligence Statement (DDS), must retain and pass on DDS references and traceability information, are exempt from showing a DDS at customs clearance if they export products.

Micro and small primary operators: are a natural person or micro/small enterprise established in a country classified as low-risk that places relevant products on the EU market or exports them, provided they produced these products themselves. They must submit a one-time simplified declaration with basic geolocation data.

Step 2: Map your products and supply chains included in the EUDR

Not all products are subject to the EUDR. Only certain commodities and their derived products are covered. The next step is to identify which of your company's products fall under the EUDR and map both the products and their origins throughout the supply chain.

Identifying your in-scope products

EUDR requires you to exercise due diligence on the products you intend to sell in the EU market or export. To do so, you must understand which raw materials you use to produce these products. Here is a simple list of what to check:

• List in-scope commodities in the raw materials used in your products.
• Match products that include the in-scope commodities to HS codes. You can check the full list of in-scope HS codes in Annex I of the Regulation.
• Map raw materials to final products.
• For each in-scope product, operators must also estimate the total annual quantity intended to be placed on the market or exported, and include this figure in their DDS submission.

Step 3: Collect and organize key data required under EUDR

Once you know what and where you're sourcing, the next step is to collect the specific data that the EUDR requires for compliance. Operators must gather a comprehensive set of information – as outlined in Article 9 – for each shipment of in-scope commodities they handle.

Required information

Geolocation data of areas of harvest: The precise GPS coordinates or polygons of the plots of land where the commodity was produced.

Production date: The date or date range when the commodity was harvested or produced. This proves that production occurred after 31 December 2020.

Product details: Description of the product (trade name, type, HS code), quantity, and shipment details.

Supply chain contacts: Names, addresses, and contact details of suppliers and buyers along the chain.

Evidence of legality: You must prove that each product was produced legally according to the laws of the country of origin. Collect documents covering: land ownership or tenure rights, harvesting or production permits, labor, environmental, and indigenous peoples' rights compliance.

Deforestation-free status: Satellite imagery, land-use history, or geotagged photos showing that no deforestation or forest degradation occurred after 31 December 2020.

Step 4: Conduct a robust EUDR risk assessment

Once your data is complete, based on Article 10, you need to assess whether there is more than negligible risk of deforestation or illegality before placing products on the EU market or exporting them.

Risk dimensions to evaluate:

• Country-level risk: Forest presence trends, deforestation and degradation trends, environmental protection levels, law enforcement, corruption levels, land use and third party issues
• Supply chain-level risk: Number of intermediaries, processing complexity, risk of mixing, non-compliant partners
• Plot/supplier-level risk: Legal permits and titles, indigenous rights, endangered species, labour and human rights violations, deforestation history, post-harvest management
• Documentation and conduct risk: Missing or unverifiable documents, supplier behavior, transparency issues, past EUDR misconduct

Assess each dimension. If any indicator suggests non-negligible risk, mitigation is required before proceeding.

Step 5: Take risk mitigation actions if needed

If your risk assessment finds anything other than negligible risk for a product, the EUDR in Article 11, requires you to take risk mitigation measures before proceeding. In practical terms, this means you must actively reduce the risk to a negligible level, or else you cannot place the product on the market.

Here's how businesses can approach risk mitigation:

• Requesting more evidence from suppliers
• Third-party verification
• On-site audits
• Supplier engagement to improve traceability or exclude non-compliant plots
• Supplier switching if risks remain

Step 6: Submit your EUDR due diligence statement

Once you have completed the due diligence process (information collection, risk assessment, and needed mitigation), the EUDR requires a formal step: submitting a due diligence statement (DDS).

Key details:

• Who submits the DDS: The company placing the product on the market
• How to submit: Through an EU's information system called EU Traces
• How frequently to submit: Every shipment needs a due diligence statement
• Special cases: Downstream operators are no longer required to submit their own DDS but must retain and pass on supplier DDS reference numbers. Micro and small primary operators in low-risk countries can submit a one-time simplified declaration instead of individual DDS submissions.

Step 7: Monitor and update over time

EUDR compliance isn't a one-time task. Companies must continuously ensure that supply chains remain deforestation-free and legally compliant.

• Ensure every new batch of in-scope products is traceable to origin before it's placed on the market.
• Monitor changes in country risk or sourcing conditions.
• Store all due diligence data, risk assessments, and statements for at least five years.
• Prepare for audits by EU authorities.

Check out our EUDR procurement integration guide to ensure supplier vetting includes compliance with the latest regulations.

Leveraging technology to simplify compliance

Managing EUDR compliance manually can quickly become overwhelming especially as supply chains grow. Digital tools make a difference by centralizing data collection, automating risk screening, live deforestation screening, supply chain mapping, due diligence statement management, and ongoing monitoring.

Leveraging technology ensures that the foundation remains strong and less labor-intensive over time. Scalable solutions like Coolset are designed to support mid-market companies in exactly this way.

Next steps for businesses

Moving forward, evaluate how prepared your business is across the seven steps. Identify gaps in supplier data, internal processes, or reporting systems and decide whether additional support is needed.

Coolset's EUDR solution helps companies collect the right data, check for deforestation risk, and file Due Diligence Statements without chasing suppliers or working in complex spreadsheets.

FAQs - EUDR compliance and due diligence

1. What is the EU Deforestation Regulation (EUDR)?

The EUDR requires companies to ensure that certain commodities (e.g. cocoa, soy, palm oil, wood) are deforestation-free and legal. Parliament voted to delay enforcement to 30 December 2026 for large and medium operators and 30 June 2027 for small and micro primary operators (non-timber).

2. Who needs to comply with EUDR?

All operators and traders handling in-scope products must comply. Operators submit a DDS. Small/micro primary operators file a simplified declaration. Downstream operators and non-SME traders no longer submit DDS but must maintain traceability and record-keeping.

3. What data is required for EUDR compliance?

Operators must collect and verify key data outlined in Article 9, including: geolocation data (GPS coordinates or polygons) of plots where commodities were produced, production dates confirming harvest took place after 31 December 2020, evidence of legality (land titles, permits, labor and indigenous rights compliance), deforestation-free proof (satellite imagery or land-use history), and supplier and buyer information (names, addresses, and contact details). This information must be stored for at least five years.

4. What does EUDR due diligence involve?

EUDR due diligence consists of seven key steps: confirm your role (operator, trader, or downstream operator), identify in-scope products and map supply chains, collect required data (geolocation, legality, production date), conduct a risk assessment (Article 10), mitigate any non-negligible risks (Article 11), submit a DDS or, where applicable, a simplified declaration, and monitor, update, and retain records for five years.

5. How are low-risk countries treated under the EUDR?

Products from low-risk countries benefit from simplified due diligence, meaning fewer risk assessment requirements, but not a full exemption. Only micro and small primary operators established in those countries may submit a one-time simplified declaration. All other operators must still perform due diligence and ensure traceability to origin plots.

6. Can technology help with EUDR compliance?

Yes. Platforms such as Coolset can simplify and automate the EUDR process by collecting and validating supplier data and geolocation information, mapping and visualizing supply chains, tracking risk and compliance in real time, managing DDS submissions through integration with the EU TRACES system, and centralizing documentation for audits and annual reporting.

7. What is the April 2026 EUDR review?

The Commission must review the EUDR by 30 April 2026, with a focus on small and micro operators. This may lead to further simplification, but any changes must go through the formal legislative process.