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Bernat Fortet

What Is the EUDR? The EU Deforestation Regulation Explained

The EUDR keeps coffee, cocoa, soy, palm oil, cattle, rubber and wood from land deforested after 2020 out of the EU. Who must comply, what to file and when.

Illustrated forest edge with young trees and flowering shrubs in a grassy clearing

The EU Deforestation Regulation (EUDR), Regulation (EU) 2023/1115, decides which coffee, cocoa, palm oil, soya, rubber, wood and cattle products can be sold in the EU or exported from it. They must come from land that was not deforested after 31 December 2020, be produced legally, and be covered by a due diligence statement from the first company to place them on the EU market. It applies from 30 December 2026, with a later date for some micro and small operators.

This guide explains the regulation for the cooperatives, exporters and importers who have to make it work. For the location data it asks for, see what geolocation the EUDR requires. For software at each step, see tools for EUDR geolocation data.

Checked October 21, 2026: against Regulation (EU) 2023/1115 as amended by ⁠2024/3234 and ⁠2025/2650, the ⁠2025 country list, the Commission's ⁠FAQ and ⁠guidance, and its ⁠review of 4 May 2026. A plain-language summary, not legal advice.

What does the EUDR cover?

Seven commodities, and the products made from them that are listed by customs code in Annex I of the regulation:

  • The commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood.
  • Products made from them: for example beef, roasted coffee, chocolate, palm oil, soya meal, tyres, wooden furniture and paper.

⁠Delegated Regulation (EU) 2026/2102 updates Annex I. From 30 December 2027 it adds soluble coffee and many palm oil derivatives, such as crude glycerol, fatty alcohols and soap. It also takes some products out, such as cattle hides and leather, exempts samples of negligible value used only to get orders, and excludes waste, second-hand goods and packaging that only carries another product.

A covered product can be placed on the EU market or exported only if it meets three conditions (Article 3):

  1. Deforestation-free. It comes from land that was not deforested after 31 December 2020. For wood, the harvest also must not have degraded the forest after that date.
  2. Legal. It was produced under the laws of the country of production: land use rights, environmental protection, forest rules, third parties' rights, labour and human rights, free, prior and informed consent, tax, anti-corruption, trade and customs.
  3. Covered by a statement. A due diligence statement, or for the smallest producers a simplified declaration, has been filed for it.

What counts as forest. The regulation uses FAO's definition: land of more than 0.5 hectares with trees taller than 5 metres and more than 10% canopy cover, or trees able to reach those thresholds there. Land mainly in agricultural or urban use is not forest. Coffee, cocoa, oil palm and rubber plantations, and agroforestry where crops are the main use, count as agricultural land. So a coffee farm planted in 2015 can qualify, and coffee planted on land cleared of forest in 2021 cannot.

Who has to comply with the EUDR?

The regulation gives each company one of three roles, depending on where it stands in the chain.

Who has to comply with the EUDR?
RoleWhoWhat they do
OperatorThe company that first places a product on the EU market, or exports itDoes due diligence and files the due diligence statement
Downstream operatorA company that sells or exports products made from goods already covered, such as a roaster or a chocolate makerFiles nothing; keeps records
TraderA company that sells covered products after they are on the market, such as a wholesaler or a supermarketFiles nothing; keeps records

Until Regulation 2025/2650, larger companies further down the chain also filed statements, referring to the earlier ones, and larger traders were treated as operators. Now only the first operator files. One exception: when a company outside the EU places the goods on the market, the first EU company to sell them on is also treated as an operator and files its own statement.

Downstream operators and traders keep the names, addresses and emails of their suppliers and customers for at least five years, and pass on any new information about risk. The first one after the operator also keeps the statement's reference number. Larger ones, beyond small and medium-sized companies, also register in the EU's information system, and when they get substantiated concerns, they check that due diligence was done before selling.

The simplified declaration. A micro or small primary operator, a farmer or small company in a low-risk country that sells what it grows itself, files a one-time simplified declaration and can give a postal address instead of geolocation. The simplified declaration replaces the due diligence statement requirement; due diligence still applies. (For everyone else, one statement can already cover several shipments.) It is for producers who place their own produce on the EU market, such as EU farmers. A farmer outside the EU who sells to a cooperative or an exporter there doesn't need one. An EU farmer selling to a cooperative may, because that sale can be the first placing on the market. Producers in standard-risk countries, such as Brazil, Colombia, Peru, Côte d'Ivoire and Ethiopia, can't use it.

Outside the EU. Farms, cooperatives and exporters that don't place goods on the EU market themselves have no legal duty under the EUDR; the Commission's FAQ says so for primary producers. An exporter that does place them, for example as the importer of record, becomes an operator. But the importer cannot file without their data, so in practice the work starts at the farm.

Outside the EU

  1. Farm

    No direct EUDR duty

    Grows the coffee. Shares where each plot is and the papers for the land.

  2. Cooperative

    No direct EUDR duty

    Buys from members and keeps their plot list and records.

  3. Exporter

    No direct EUDR duty

    Sells to the EU importer and sends the plot data with each lot.

In the EU

  1. EU importer

    Operator: files the statement

    First to place the coffee on the EU market. Does due diligence and files the due diligence statement.

  2. Roaster, then retailer

    Files nothing, keeps records

    The roaster keeps the importer’s reference number. Each keeps who it bought from and sold to.

What does due diligence mean under the EUDR?

Three steps, which the operator repeats for every product it places on the market (Articles 8 to 11):

  1. Collect the information. What the product is and how much, the country of production, the geolocation of every plot it came from and when it was produced, who supplied it and who it goes to, and evidence that it is deforestation-free and legal.
  2. Assess the risk. Check that information against the risk criteria in Article 10: the country's risk level, forest cover and indigenous peoples in the area, how complex the supply chain is, and the risk of mixing with products of unknown origin. Certification can inform this step.
  3. Mitigate the risk. If the risk is more than negligible, reduce it: ask for more documents, commission independent surveys or audits, or support suppliers to fix the problem. Until the risk is negligible, the product can't be placed on the market.

Simplified due diligence. When everything comes from low-risk countries, the operator still collects the information and checks that the chain is not being used to pass off products from elsewhere, but skips steps 2 and 3 (Article 13). The full steps come back if it learns of a risk.

Operators review their due diligence system at least once a year.

What location data does the EUDR need?

The location of every plot of land where the commodity was produced: at least one latitude and longitude point with six decimal places, or a polygon for plots of more than 4 hectares. For cattle, it is every establishment where the animals were kept. Files go up as GeoJSON in WGS84.

The details, with an example file and the mistakes that get files rejected, are in what geolocation the EUDR requires.

What is a due diligence statement?

A short declaration, filed in the EU's EUDR Information System (hosted on TRACES), that the operator did due diligence and found no risk or only a negligible one. It carries the operator's details, the product's customs code and quantity, the country of production and the geolocation of the plots.

  • Reference number. The system returns a reference number for each statement, plus a verification number. Customs need the reference number before the goods are released or exported.
  • Records. Operators keep statements and the information behind them for five years.
  • Size. A statement can be up to 25 MB including its geolocation, a system limit rather than a rule in the regulation. Statements can be grouped when one file isn't enough.

How is the EUDR enforced?

Each EU country's competent authority checks companies, using the country ratings the Commission set in ⁠Implementing Regulation (EU) 2025/1093.

How is the EUDR enforced?
Country riskCountries (2025 list)Checks each year, at least
LowThe EU, the United States, China, the United Kingdom, India, Vietnam, Ghana and many others1% of operators
StandardEvery country not listed, including Brazil, Colombia, Peru, Côte d'Ivoire, Ethiopia, Indonesia and Malaysia3% of operators
HighBelarus, Myanmar, North Korea and Russia9% of operators, and 9% of the quantity of each product

The check rates also count larger downstream operators and traders. A low-risk rating allows simplified due diligence; it doesn't exempt anyone from the rules.

Penalties are set by each country, within limits the regulation fixes (Article 25):

  • A maximum fine of at least 4% of the company's annual EU turnover.
  • Confiscation of the products, and of the revenue from them.
  • Exclusion from public procurement and public funding for up to 12 months.
  • For serious or repeated breaches, a temporary ban on placing products on the market, and the loss of simplified due diligence.

When does the EUDR apply?

The EUDR has been in force since 2023, but its obligations have been delayed twice.

When does the EUDR apply?
DateWhat happened
29 June 2023The regulation enters into force
23 December 2024First delay, by Regulation (EU) 2024/3234: one more year
23 December 2025Second delay and simplification, by Regulation (EU) 2025/2650: only the first operator files, and the simplified declaration is created
4 May 2026The Commission's review proposes no new amendment or delay, and restates 30 December 2026
17 September 2026Delegated Regulation (EU) 2026/2102 updates the product list in Annex I
30 December 2026Obligations apply to most companies; the old EU Timber Regulation is repealed
30 June 2027Obligations apply to micro and small companies and individuals established as such by 31 December 2024, except for products from the old Timber Regulation
30 December 2027Soluble coffee and the new palm oil derivatives join the scope

The review is in ⁠COM(2026) 191. It estimates that all the simplifications since 2023, including the 2025 amendment, cut annual compliance costs by about 75%, and it went out with an updated FAQ, new guidance and the draft Annex I update, which has since been adopted. A wider review of the regulation is due by 30 June 2030.

What do people get wrong about the EUDR?

  • "We need an EUDR certificate." The regulation creates no certificate or label. Schemes such as Rainforest Alliance or FSC can support a risk assessment, but the Commission's guidance says they cannot replace the operator's due diligence. What shows a product is covered is its statement's reference number.
  • "The EU forest map decides." The JRC Global Forest Cover 2020 map on the EU Observatory is a reference, not the legal baseline. The Commission's FAQ calls it non-mandatory and not legally binding. A plot inside mapped forest isn't automatically out, and a plot outside it isn't automatically in.
  • "Deforestation-free means compliant." Legality is a separate test. A plot with no forest loss still fails if the land was taken without the right to use it, or the coffee was grown in breach of labour laws.
  • "It doesn't apply to us; we're outside the EU." Legally true for most cooperatives and exporters. Commercially, a buyer who can't get plot data can't file, and won't buy.
  • "Agroforestry coffee is forest." Not when farming is the main use of the land. Coffee or cocoa under shade trees counts as agriculture and can qualify. Coffee picked as a minor crop inside natural forest is still forest.

Where to start

For most cooperatives and exporters, the EUDR comes down to one list: every plot, its producer and its location, kept current, with the land documents behind it. What geolocation the EUDR requires covers the location rules. Tools for EUDR geolocation data covers the software for mapping, checking and filing.

Learn everything about the EUDR

From what the regulation asks to mapping plots, tracing lots and reviewing the evidence, in the order teams need it.

Open the EUDR Guide

Frequently asked questions

What is the EUDR?

The EU Deforestation Regulation, Regulation (EU) 2023/1115. It allows cattle, cocoa, coffee, oil palm, rubber, soya and wood, and products made from them, onto the EU market or out of it only if they come from land not deforested after 31 December 2020, were produced legally in their country and are covered by a due diligence statement.

When does the EUDR apply?

The rules apply from 30 December 2026. Qualifying micro and small operators established as such by 31 December 2024 have until 30 June 2027, except for products from the old EU Timber Regulation. Traders and downstream operators follow the December 2026 date. The dates come from Regulation (EU) 2025/2650. The Commission's review of 4 May 2026 proposed no further delay.

Does the EUDR apply to farmers and cooperatives outside the EU?

Not directly. The Commission's FAQ says the regulation places no legal obligations on non-EU countries, and a non-EU company only becomes an operator if it places goods on the EU market itself. In practice, the EU buyer needs the plot locations and verifiable evidence of legal production, including land-use rights, which farms, cooperatives and exporters supply.

Who files the due diligence statement?

The operator, the company that first places the product on the EU market or exports it, which for imported coffee or cocoa is usually the EU importer. Since Regulation (EU) 2025/2650, companies further down the chain, such as roasters and retailers, no longer file statements. The first of them keeps the statement's reference number.

What is the EUDR simplified declaration?

A one-time declaration that micro and small primary operators in low-risk countries file when they place what they grow themselves on the EU market (Article 4a). It replaces the due diligence statement requirement and can give a postal address instead of geolocation; due diligence still applies.

Is there an EUDR certificate?

No. The regulation creates no certificate or label. Certification schemes can feed into an operator's risk assessment, but the Commission's guidance says they cannot replace its due diligence. What shows that a product was covered is the reference number of its due diligence statement.

What happens if a company does not comply with the EUDR?

Each EU country sets its own penalties within limits the regulation fixes. They include a maximum fine of at least 4% of the company's annual EU turnover, confiscation of the products and of the revenue from them, and exclusion from public procurement and public funding for up to 12 months.

Another question? Email us or book a call.

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