Why the EUDR matters

Deforestation remains a critical global issue, fueling climate change and biodiversity loss. In 2022, the world lost primary tropical forest at a rate of about 11 football fields every minute. This rampant forest clearance is largely driven by agricultural expansion – for example, cattle ranching, soy farming, palm oil plantations and other commercial agriculture caused roughly 40% of tropical deforestation from 2000 to 2010. The environmental consequences are severe: deforestation contributes around 12% of annual global greenhouse gas emissions and destroys habitats that sustain 80% of the planet’s land-based wildlife.

The European Union plays a significant role in this problem as a major consumer market. The EU has been the world’s second-largest driver of tropical deforestation after China due to its imports of commodities like beef, soy, palm oil, coffee, cocoa, rubber, and wood products. One WWF study found the EU responsible for 16% of deforestation linked to international trade.

What is the EU Deforestation Regulation?

The EU Deforestation Regulation (Regulation (EU) 2023/1115) is the EU’s law to keep deforestation and forest degradation out of supply chains. It repeals the EU Timber Regulation, which since 2013 had prohibited illegal timber imports, and applies to seven commodities and many derived products. It was formally adopted in 2022 and entered into force on June 29, 2023. Following a second postponement, the legally binding start for market obligations is now 30 December 2026 for large and medium operators, and 30 June 2027 for micro and small operators. This was confirmed when the amended Regulation (EU) 2025/2650 was published in the Official Journal on 23 December 2025 and entered into force on 26 December 2025.

The EUDR builds on the EU’s prior efforts to fight deforestation – it actually repeals and replaces the older EU Timber Regulation (EUTR), which since 2013 had prohibited illegal timber imports. The new regulation significantly expands the scope beyond timber, covering a broader set of commodities responsible for forest loss. It is also more stringent: rather than targeting only illegal deforestation (as the EUTR did for illegal logging), the EUDR targets all deforestation regardless of legality, after a certain cutoff date.

At its core, the EUDR prohibits the placing of specific high-risk commodities on the EU market (or exporting them from the EU) unless the products are verified to be:

(a) "deforestation-free," and;

(b) produced in accordance with the laws of the country of origin.

In addition, each in-scope product must be covered by a Due Diligence Statement (DDS) attesting to compliance. These requirements apply to all operators and traders dealing in the relevant commodities and products, whether they are based in the EU or outside it (as long as they place goods on the EU market).

What does "deforestation-free" mean?

Under the EUDR, "deforestation-free" is defined in relation to a specific cutoff date: December 31, 2020. This means that any product placed on the EU market must not have been produced on land where deforestation or forest degradation occurred after this date. In practical terms:

• If a farm was converted from forest to cropland after Dec 31, 2020, products from that farm cannot be sold in the EU under the EUDR.
• If the farmland was already established before 2020 (or the commodity was sourced from land where no forest was lost after 2020), the products can qualify as deforestation-free.

This approach effectively grandfathers existing agricultural land as of 2020 and creates a firm line against any further forest clearance for commodity production.

Objectives of the EUDR

The EUDR has several overarching goals:

• Halt EU-driven deforestation: By requiring that products entering the EU market are free from recent deforestation, the regulation aims to cut the EU’s contribution to global forest loss.
• Protect biodiversity and climate: Forests are critical carbon sinks and biodiversity reservoirs. By preserving them, the EUDR supports the EU’s climate goals under the European Green Deal and international biodiversity targets (such as the Kunming-Montreal Global Biodiversity Framework).
• Ensure sustainable supply chains: Companies will need greater transparency and traceability in their supply chains, which can also lead to better governance and reduced corruption in forestry and agriculture sectors.
• Ensure legality: Besides being deforestation-free, products must comply with the relevant laws of the producing country (including land-use, environmental, human rights, and trade laws).

When do EUDR obligations start for different companies?

Although the EU Deforestation Regulation (EUDR) entered into force in mid-2023, there has been a delay alongside many regulatory proposals which have put the timeline into uncertainty. Below is a timeline of what’s currently legally binding, alongside proposed changes that are still under review.

Key dates to know:

June 29, 2023: The EUDR entered into force. From this point, it became official EU law, although compliance obligations were not yet active. Companies were expected to begin preparations early.

May 20, 2025: The European Commission published the first country risk benchmarking classifications: 140 countries classified as low-risk (including all EU Member States, the US, Canada, China, Ukraine, and Thailand), 4 countries as high-risk (Belarus, Myanmar, North Korea, and Russia), and all remaining countries as standard-risk.

October, 2025: The Commission suggested deferring the general deadline to 30 December 2026 and introducing a one-time simplified declaration for micro and small primary operators.

November, 2025: EU Parliament adopted a set of amendments, including:

• Deferring obligations for large and medium operators to 30 December 2026 and for small/micro operators to 30 June 2027
• Clarifying exemptions for small and micro primary producers
• Removing redundant data-sharing obligations from downstream operators
• Excluding printed paper products (e.g. books) from scope

December, 2025: The amended regulation (Regulation (EU) 2025/2650) was formally adopted following trilogue agreement on 4 December, Parliament adoption on 17 December, and Council endorsement on 18 December. It was published in the Official Journal on 23 December 2025 and entered into force on 26 December 2025. The binding deadlines are now 30 December 2026 for large and medium operators and 30 June 2027 for micro and small operators.

What commodities and actors are covered?

The EUDR covers seven key commodities that have been identified as major drivers of deforestation globally. These are:

1. Cattle
2. Cocoa
3. Coffee
4. Oil palm
5. Rubber
6. Soy
7. Wood

It’s important to note that the regulation applies not only to these raw commodities but also to a wide range of derived products. For instance, under palm oil, products like chocolate, cosmetics, or biofuels that contain palm oil derivatives are covered. Under cattle, leather goods and processed meat products fall in scope. The full product list is detailed in the regulation’s annex and references customs codes (CN codes) for clarity.

If a product contains or is made from one of these seven commodities – whether directly as an ingredient or used in production—like palm oil derivatives in cosmetics or soy-based cattle feed in meat production—the end product still falls under the EUDR. Companies must assess each product in their portfolio to determine if it includes any EUDR-relevant components.

Who must comply?

The EUDR applies to three categories of market participants: operators, downstream operators, and traders. While their roles and responsibilities differ, all are essential in ensuring only deforestation-free products enter or circulate within the EU market. For a detailed breakdown by sector and role, see who needs to comply with the EUDR.

Note: The December 2025 amendments (Regulation 2025/2650) are now in force and have adjusted several obligations - see details below.

Operators

Operators are companies or individuals who place relevant commodities or derived products on the EU market or export them from the EU. This includes:

• Importers bringing covered goods into the EU
• EU-based manufacturers placing finished products on the EU market
• Any company, inside or outside the EU, that introduces a regulated product into the EU supply chain for the first time
  

Operators carry the primary responsibility for EUDR compliance. This means they must conduct and document full due diligence to ensure that products are deforestation-free and legally produced. For example, a coffee importer sourcing beans from Brazil is considered an operator and must trace those beans back to verified, compliant plots of land.

Important: The amended EUDR (Regulation 2025/2650), small and micro primary operators based in low-risk countries may submit a one-time simplified declaration instead of full due diligence. Additionally, SMEs can use postal codes instead of precise geolocation coordinates for traceability. For a step-by-step walkthrough, see the EUDR reporting guide for operators.

Downstream operators

The amended EUDR (Regulation 2025/2650) introduced a distinct downstream operator category. Downstream operators are companies that handle EUDR-relevant products after the first operator has placed them on the EU market - for example, a food manufacturer sourcing palm oil from an importer who already filed the initial due diligence statement.

Under the amended regulation, downstream operators are not required to submit their own due diligence statements. Instead, they must:

• Collect and retain the DDS reference number from their supplier (the first operator)
• Verify that their supplier has filed a valid DDS for the products in question
• Refrain from placing products on the market if they know or suspect non-compliance

This change significantly reduces the administrative burden for companies further down the supply chain. Previously, each actor would have needed to conduct separate due diligence. Now, only the first operator placing the product on the EU market carries the full due diligence obligation.

Traders

Traders are companies that make EUDR-regulated products available on the EU market, but are not the first to place them there. These include:

• Wholesalers
• Distributors
• Retailers
  

Traders have lighter obligations than operators, particularly if they are classified as micro or small enterprises. In most cases, they are required to:

• Ensure that upstream operators have completed due diligence
• Pass along relevant compliance information (e.g., due diligence statement references)
• Avoid placing non-compliant products on the market

Important: The amended EUDR (Regulation 2025/2650), only the first downstream operator must collect and store DDS references. Other downstream traders (including SME traders) no longer need to pass them on, easing traceability obligations.

Due diligence requirements: what companies must do

The heart of the EUDR is its due diligence system, which operators must follow before placing a regulated product on the EU market. The process is structured around three main steps:

1. Collect information

Companies must gather detailed data about the products they are importing or placing on the market. The EUDR specifies the information that must be collected, which includes:

• A description of the product (commodity and derived products, quantities, and the relevant customs codes).
• The country and region of production.
• Geolocation data: For agricultural products, the GPS coordinates of the specific plots of land where the commodity was grown or produced. This is a critical and novel requirement, ensuring traceability to the origin farm or forest. For large plots, a polygon outline may be needed; for smaller ones, a single geopoint may suffice.
• Evidence that the product is deforestation-free (produced without deforestation after Dec 31, 2020) and legally produced (in compliance with the origin country’s laws on land use, environment, labor, etc.).
• Supplier and buyer information for the product in the supply chain.

This step essentially builds a detailed information file for each shipment or batch of products, which forms the basis for the subsequent risk analysis.

2. Assess risk

Once the data is collected, the next step is to evaluate the likelihood that the product may be non-compliant. This risk assessment must be based on objective criteria, including:

• The complexity of the supply chain
• The prevalence of deforestation in the country or region of origin
• The presence of indigenous or customary land rights
• Corruption or governance issues in the source country
• Whether the commodity is known to be associated with deforestation (e.g. palm oil or soy in certain regions)

The operator must conclude whether there is a "negligible risk" or "more than negligible risk" that the product is linked to deforestation or non-compliance. If the risk is more than negligible—or if the company cannot confidently rule out risk—then the product cannot move forward without further action.

This means companies must have systems in place to document their evaluations, justify their decisions, and demonstrate a clear methodology for reaching a “negligible risk” conclusion. For a practical walkthrough, see the EUDR risk assessment guide.

3. Mitigate risk

If the risk assessment reveals any concerns (i.e. risk is not negligible), the company must take steps to reduce or eliminate the identified risk. Risk mitigation measures could include:

• Requesting additional documentation or independent audits of the supply chain.
• Conducting on-the-ground checks or third-party verifications of farms or logging operations.
• Engaging with suppliers to obtain satellite data or certification evidence for the relevant plots.

The goal is to bring the risk down to a "negligible" level. Only when the operator is satisfied that the risk of non-compliance is negligible can they proceed to place the product on the market. If risk cannot be adequately mitigated, the product should not enter the EU market.

Submitting a due diligence statement

After completing the above steps, the operator must submit a Due Diligence Statement (DDS) to the relevant authority via the EUDR Information System. The DDS is a formal declaration that due diligence has been conducted and that the product meets EUDR requirements. Each DDS covers a specific product consignment, and the operator is legally accountable for its accuracy.

DDS requirements under the amended EUDR

In submitting a DDS, operators should note that the following rules apply to DDS obligations under the amended EUDR (Regulation 2025/2650):

• Traceability duties related to DDS numbers apply only to the first downstream operator, who is responsible for collecting and keeping them.
• Downstream operators are no longer required to pass DDS numbers further along the supply chain.
• DDS numbers only need to be collected when the supplier is an operator, not a trader.
• Micro and small primary operators in low-risk countries are exempt from submitting a full DDS and instead may submit a simplified declaration once.

Ensuring traceability

Traceability is a cornerstone of the EUDR. The regulation effectively requires a documented chain from the final product all the way back to the piece of land where the raw material was grown or harvested. Companies must be able to show, for any given product, where the commodity came from (with GPS coordinates of the plot of land), when it was produced, and that no deforestation occurred on that land after Dec 31, 2020.

This level of traceability is one of the EUDR’s most ambitious and technically challenging demands. It goes beyond what many companies currently track in their supply chains. In practice, ensuring traceability may involve:

• Working directly with first-mile suppliers or farms to collect geolocation data of production areas.
  
• Using satellite monitoring or geospatial analysis services to verify that the plots in question have not undergone deforestation.
• Establishing data-sharing agreements or platforms across the supply chain, so that information can flow from the origin country to the EU importer.
• Keeping detailed records for each consignment linking the product to the compliance data (origin, DDS reference, etc.).
  

What about traders?

Under the EU Deforestation Regulation (EUDR), traders, particularly small and micro enterprises, have reduced obligations compared to operators. If you’re a distributor or retailer buying from an operator:

• You do not have to repeat the full due diligence
• You must obtain and retain the due diligence statement or its reference from your supplier
• You must not trade in products you know- or should reasonably suspect, are non-compliant

Each actor in the supply chain must preserve the flow of information. By the time a product reaches a retail shelf, there must be a clear and documented trail back to the compliant plot of land. Traders must also be prepared to respond to regulatory inquiries and cooperate with inspections. While the burden of data collection, geolocation, and risk assessment sits primarily with the operator, responsibility is shared across the chain.

Important: Under the amended EUDR (Regulation 2025/2650), traders are only required to retain DDS references when their supplier is an operator, and the obligation to pass DDS numbers further down the chain has been removed. Only the first downstream operator must collect and store DDS numbers. For role-specific guidance, see the reporting guides for traders and SMEs.

What do you need to keep in mind?

Regardless of whether you are an operator, downstream operator, or trader, the EUDR holds everyone in the supply chain to a standard of accountability. Even companies that are not directly importing can face penalties if they knowingly deal in non-compliant products. Therefore, even if you are "just a trader," it’s important to know your obligations and to demand transparency from your suppliers.

The multi-layered approach extends to multi-ingredient products—each relevant commodity must be separately assessed and traced. For example, if you import a cosmetic product containing both palm oil and cocoa derivatives, you must ensure EUDR compliance for both commodities in that product.

Ensuring full traceability across complex, multi-tier supply chains is one of the largest practical challenges under the EUDR. Many companies have limited visibility beyond their first-tier suppliers, often across borders and languages. But in return, the regulation offers a path to more sustainable, transparent supply chains.

Country risk classification: changes in benchmarking

The Commission published its first country benchmarking list on May 20, 2025, classifying 140 countries as low-risk (including all EU Member States, the US, Canada, China, Ukraine, and Thailand), 4 countries as high-risk (Belarus, Myanmar, North Korea, and Russia), and the rest as standard-risk. On July 9, 2025, the European Parliament voted (373 to 289) to reject this classification, citing reliance on outdated data, lack of transparency, and concerns over political bias. Despite this rejection, the amended regulation (2025/2650) maintained the benchmarking framework. The first review of classifications is scheduled for 2026, using updated FAO Global Forest Resources Assessment data. The Commission is exploring several approaches to improve the system:

• Technical revision of the benchmarking system, preserving the system to remain credible while addressing legitimate concerns. Maintaining the three risk categories but improving data quality, transparency, and regional differentiation within countries.
• Introduction of a "no-risk" category, pushed by political groups advocating for deregulation. This scenario would reduce or remove due diligence obligations for some countries - potentially undermining the EUDR’s purpose by opening loopholes in the supply chain.‍
• ‍Reopening the EUDR itself for broader changes, using the benchmarking debate as a lever to delay implementation or weaken key provisions. Although less likely, this option reflects wider political pressures on EU regulatory frameworks.

The following are the three original risk categories:

‍Low-risk countries

Commodities sourced entirely from low-risk areas can follow a simplified due diligence procedure. Companies must still collect all basic information - such as geolocation data, production details, and legal compliance evidence - but the formal risk assessment step (Article 10) can be streamlined. The underlying rationale: if a country has strong forest governance and low deforestation rates, the baseline risk is lower, and thus less mitigation is needed.

‍Standard-risk countries

This is the default risk level. Operators must follow the full due diligence process, including detailed risk assessment and mitigation steps. There is no reduction in obligations for standard-risk countries. It is worth noting that under the EUDR, every country starts as standard-risk until the Commission’s benchmarking exercise assigns a different level.

‍High-risk countries

Operators importing from high-risk countries face enhanced due diligence requirements. This includes stricter inspection targets by competent authorities (at least 9% of operators by volume of relevant products). In practical terms, high-risk sourcing requires extra scrutiny - third-party verification, independent audits, and ongoing monitoring of the relevant supply chain might be needed to demonstrate negligible risk.

Why the benchmarking system still matters

The core of the EUDR remains unchanged. Companies importing, trading, or exporting cattle, palm oil, soy, wood, cocoa, coffee, rubber, or their derivatives must comply with the regulation by 30 December 2026 (or 30 June 2027 for micro and small operators). The Commission’s response to political pressure will determine how the benchmarking system evolves. Whether through technical revisions or broader changes, businesses should stay on track with EUDR preparations. Learn how to build your due diligence system under the latest updates on EUDR benchmarking.

Enforcement and penalties

A regulation is only as good as its enforcement. Under the EUDR, EU Member States are responsible for enforcing the law through their designated competent authorities (for example, customs authorities, environmental agencies, or other regulators appointed at the national level). These authorities will conduct checks on companies to ensure they are complying with the due diligence requirements and not placing non-compliant products on the market.

How will enforcement work? Competent authorities will use a mix of audits, document reviews, and possibly on-the-ground inspections. They may:

• Check due diligence statements and reports: Authorities can request to see the due diligence documentation a company has for a particular shipment or product. They might examine the geolocation data, the risk assessment records, etc., to verify that the company indeed did what the law requires.
  
  
• Physical inspections: At border points or warehouses, they may inspect shipments. Inspection rates are risk-tiered under the amended regulation: 1% of shipments from low-risk countries, 3% from standard-risk countries, and 9% from high-risk countries. Competent authority enforcement obligations begin 30 June 2026. They might also use satellite data or cooperation with third countries to spot-check if a given batch truly originates from a deforestation-free area.
  
  
• Market surveillance: Authorities may monitor the market for products that appear non-compliant (for example, unusually cheap products from high-risk regions with no proper documentation).

There are significant penalties for non-compliance. While the exact penalties will be set by each Member State’s national law, the EUDR sets minimum provisions for what penalties should include:

• Fines proportionate to environmental damage and product value: The regulation stipulates that fines should be at least 4% of the company’s annual EU turnover for serious violations. This is a substantial threat, especially for large multinational companies.
  
  
• Confiscation of products and revenues: Non-compliant goods can be seized, and any profits derived from them can be confiscated.
  
  
• Exclusion from public procurement and funding: A company found in serious violation could be barred from participating in public procurement processes or receiving public funding for a period.
  
  
• Temporary bans from the market: In severe cases, a company could be prohibited from placing products on the EU market (or even from receiving EU funding) for a certain period, effectively a trading ban until they can demonstrate compliance.
  
  
• Prohibition of product placement: Competent authorities can order that a non-compliant product be withdrawn or recalled from the market.
  
  

These enforcement measures are designed to give the regulation real teeth. Combined with the requirement for information sharing between Member States and with the European Commission, the EUDR aims to create a coordinated enforcement framework across the EU. Companies should treat the EUDR compliance much like other major regulations (e.g. GDPR or AML rules) – the cost of non-compliance can far exceed the cost of building a proper due diligence system.

For a deeper look at the enforcement regime, read our article on EUDR compliance and enforcement and the EU’s own guidelines documents.

In terms of broader market impact, the enforcement infrastructure is still being built. Member States differ in how advanced their competent authorities are, and the effectiveness of EUDR enforcement will depend on consistent implementation across the EU. The European Commission plans to monitor enforcement activities and may step in with further guidance if enforcement is uneven. A centralized public database linking operators to their due diligence statements is also in the works, which will aid oversight.

How the EUDR complements other EU sustainability policies

The EUDR is part of a much larger framework of policies aimed at making the EU economy more sustainable. Understanding these connections can help companies find efficiencies and align compliance efforts across multiple regulations:

1. European Green Deal and Biodiversity Strategy

The EUDR is a direct outcome of the EU’s biodiversity strategy, which is part of the European Green Deal. The Green Deal set the overarching goal of making the EU climate-neutral by 2050, and protecting biodiversity is integral to that. The EUDR contributes by addressing deforestation linked to consumption. Companies working on EUDR compliance may also find it helps them align with biodiversity goals and climate commitments under the Green Deal.

2. Corporate Sustainability Due Diligence Directive (CSDDD)

The EU’s CSDDD requires large companies to conduct broad human rights and environmental due diligence across their supply chains. There is clear overlap with the EUDR’s requirements. Companies that set up robust environmental due diligence systems for EUDR (e.g. supplier engagement, risk assessment, monitoring) will likely be well-placed to meet CSDDD requirements for environmental due diligence. Integrating EUDR compliance into a wider supply chain due diligence framework can save effort and ensure consistency.

For a complete map of how EUDR fits alongside CSRD, CSDDD, CBAM, PPWR and Scope 1-3 obligations, see which EU regulations affect your supply chain.

3. Corporate Sustainability Reporting Directive (CSRD)

The CSRD requires companies to report on sustainability matters, including environmental impacts and risks. Companies subject to both CSRD and EUDR can leverage the data gathered for EUDR due diligence in their sustainability reports. For instance, information on deforestation risk in supply chains, sourcing of commodities, and traceability achievements could feed into CSRD disclosures on topics like biodiversity and land use (ESRS E4 – Biodiversity, LULUCF, etc.).

4. EU Climate Policies

The EUDR supports the EU’s climate agenda by targeting a significant source of greenhouse gas emissions. Deforestation and land-use change are responsible for a large portion of global emissions. By curtailing deforestation in its supply chains, the EU reduces its climate footprint. This complements other EU climate policies such as the Land Use, Land-Use Change and Forestry (LULUCF) regulation and the overall Fit for 55 package of climate legislation.

6. Global Biodiversity Framework

Globally, the Kunming-Montreal Global Biodiversity Framework (adopted in 2022) set targets for protecting natural ecosystems. The EUDR aligns with these targets.

Preparing for compliance: a practical checklist for companies

If your company is affected by the EUDR, early action is essential. Here’s a clear roadmap to get ready:

Note: Certain obligations in this checklist may differ for micro and small primary operators in low-risk countries, who follow a simplified declaration process under the amended EUDR (Regulation 2025/2650). For a full walkthrough, see the step-by-step EUDR compliance guide.

1. Assign responsibility and align internally

• Designate a EUDR compliance lead or team.
• Align legal, procurement, sustainability, and operations on the regulation’s implications.
• Decide where the EUDR sits in your governance structure, how it overlaps with existing sustainability or supply chain programs, and who owns each step.

2. Determine scope and responsibilities

• Identify all products in your portfolio that fall under the EUDR.
• Classify your role: Are you an operator, downstream operator, or trader?
• Map obligations accordingly. Operators must build full due diligence systems; traders must verify and retain compliance documentation.

3. Review sourcing and engage suppliers

• List sourcing countries and regions.
• Research deforestation risks for each origin.
• Begin conversations with suppliers to:
  
  • Request geolocation data (GPS coordinates) and production dates. See our guide on collecting EUDR data from suppliers for practical tips.
  • Ensure understanding of EUDR compliance expectations.
  • Update contracts to require deforestation-free sourcing and information sharing.
• Evaluate supplier readiness and prioritize engagement where risks are highest.

4. Build your due diligence system

• Establish internal procedures for EUDR due diligence (information collection, risk assessment, risk mitigation).
• Develop templates or checklists for each product/commodity.
• Define clear criteria for what constitutes "negligible risk" vs. risk requiring further action.

5. Implement traceability and risk assessment technology

• Identify and evaluate technology solutions for:
  • Collecting and managing geolocation data from suppliers
  • Performing deforestation risk checks (e.g. satellite-based monitoring)
  • Storing and sharing due diligence records and DDS submissions
• Consider integration with existing supply chain management or ERP systems.

6. Manage geolocation and data properly

• Centralize geolocation data (GPS coordinates) for all sourcing plots.
• Ensure data quality and consistency, cross-reference with satellite imagery where possible.
• Maintain records accessible for audit and regulatory inspection.

7. Document everything systematically

• Keep all due diligence records for at least 5 years.
• Store DDS submissions, geolocation files, risk assessments, and supplier correspondence in a structured, accessible system.

8. Pilot and refine

• Use 2026 to pilot your processes on selected supply chains.
• Test collection of geolocation data, risk assessments, and due diligence statement submissions.
• Identify gaps and improve workflows before the EUDR obligations go live.
  

9. Stay updated and flexible

• Monitor EUDR developments, especially around the country risk benchmarking revisions expected in 2026.
• Subscribe to updates from the European Commission and from industry associations in your sector.
• Adjust your compliance plan as new guidance or amendments emerge.

10. Leverage synergies and external expertise if needed

• Align EUDR work with other compliance projects (e.g., ethical sourcing, human rights due diligence).
• Consider collaborating with industry initiatives, consultants, or traceability solution providers to accelerate readiness.

Important: Under the amended EUDR (Regulation 2025/2650), requirements related to due diligence statements, data handling, and administrative responsibilities are reduced for micro and small primary operators in low-risk countries. Consider using specialized EUDR compliance tools to streamline the process.

These changes are explained in more detail in this deep-dive article.

The path forward: turning compliance into opportunity

The EU Deforestation Regulation marks a major shift toward transparent, responsible supply chains. It doesn’t ban trade - it steers it toward sustainability.

Companies that prepare early can turn compliance into an opportunity, gaining competitive advantage and securing their place in a future where deforestation-free sourcing will be the norm.

The EUDR also supports Europe’s wider climate and biodiversity goals and is likely to set a global standard, with similar rules emerging in the UK and US.

For businesses, acting now isn’t just about avoiding penalties, it’s about building resilient, future-proof operations. Those who adapt early will lead the change toward a more sustainable global economy.

Coolset’s EUDR product helps companies collect the right data, check for deforestation risk, and file Due Diligence Statements without chasing suppliers or working in complex spreadsheets. With Coolset, companies can import product and order data from your ERP, request documents from suppliers, and track everything in one place. The system flags missing or at-risk shipments and generates audit-ready DDS files that follow the mandatory EU TRACES format.

See Coolset’s EUDR module in action. Request demo today.

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FAQs – EUDR compliance and deadlines

1. What is the EUDR and who must comply?

The EU Deforestation Regulation (EUDR) is a law that bans the sale or export of products linked to deforestation in the EU. Any company that places or exports covered commodities (like soy, beef, cocoa, or timber) on the EU market must comply - including both EU and non-EU companies.

2. Which products are affected by the EUDR?

The EUDR covers seven commodities - cattle, cocoa, coffee, oil palm, rubber, soy, and wood - plus a wide range of derived products (e.g. leather, chocolate, furniture, biofuels). The full product list references specific customs codes.

3. What does "deforestation-free" mean under the EUDR?

A product is considered deforestation-free if the raw materials used were produced on land that has not been subject to deforestation after December 31, 2020. This includes both legal and illegal deforestation - the EUDR does not distinguish.

4. When do EUDR requirements take effect?

Following the second postponement confirmed in December 2025 (Regulation 2025/2650), the binding deadlines are 30 December 2026 for large and medium operators and 30 June 2027 for micro and small operators. Micro and small primary operators previously covered by the EU Timber Regulation must comply by 30 December 2026.

5. What are the due diligence steps required by the EUDR?

Operators must:

1. Collect supply chain data (including farm geolocation)
2. Assess deforestation risk
3. Mitigate any risk to “negligible”
4. Submit a due diligence statement for each shipment