EUDR Compliance Guide 2026: Deadlines, Requirements & Due Diligence | Payload Website Template

What is the EU Deforestation Regulation (EUDR)?

The EU Deforestation Regulation — formally Regulation (EU) 2023/1115 — is the European Union's flagship law for keeping deforestation out of its supply chains. Its logic is simple: if a product made from cattle, cocoa, coffee, oil palm, rubber, soya, or wood comes from land deforested after 31 December 2020, it cannot be sold in the EU or exported from it. Period.

For businesses, EUDR compliance means three things in practice: tracing your supply chain back to the exact plot of land, proving that production was both deforestation-free and legal, and filing a Due Diligence Statement (DDS) in the EU's TRACES information system before goods cross the border.

The regulation entered into force in June 2023, but its main obligations have been postponed twice. They now begin to apply on 30 December 2026 for large and medium companies, and on 30 June 2027 for micro and small operators. The most recent amendment, Regulation (EU) 2025/2650, was published in the Official Journal of the EU on 23 December 2025 and also simplified several parts of the original law.

If you sell coffee, chocolate, leather goods, palm oil derivatives, furniture, paper, or beef into the EU — or you source any of these — the EUDR will reshape how you document your supply chain.

EUDR vs EUTR: what changed from the old timber regulation

The EUDR did not appear from nowhere. It replaces the older EU Timber Regulation (EUTR), Regulation (EU) No 995/2010, which has governed timber imports into the EU since 2013. The shift from EUTR to EUDR is significant in three ways:

Scope. EUTR covered only timber and timber products. EUDR covers seven commodities — cattle, cocoa, coffee, oil palm, rubber, soya, and wood — plus a long list of derived products.
The "deforestation-free" bar. EUTR required only that timber be legally harvested. EUDR adds a second, stricter requirement: the product must also be deforestation-free as of 31 December 2020, regardless of whether the deforestation was legal in the country of origin.
Geolocation and digital reporting. EUTR required basic supplier information. EUDR requires geolocation coordinates of the specific plot of land, filed electronically through the TRACES system as part of a formal Due Diligence Statement.

If you previously complied with EUTR for timber, you already have a head start — but the EUDR's geolocation requirement and the expanded commodity list mean significant new work.

Key EUDR terms you need to know first

Before going further, four terms do most of the heavy lifting in the EUDR. Get these straight and the rest of the law becomes much easier to follow.

Operator — the company that first places a product on the EU market, or that exports it from the EU. Think of an operator as the entry point into the EU's regulatory perimeter.
Trader — anyone in the supply chain who makes a product available after the operator has placed it on the market. Most distributors and retailers are traders, not operators.
Due Diligence Statement (DDS) — the electronic declaration submitted to the EU's central information system (TRACES). It contains geolocation coordinates of the plot of land where the commodity was produced, and a confirmation that the operator has done its due diligence.
Competent Authority — the national body in each EU member state responsible for enforcing the EUDR (carrying out checks, imposing penalties, etc.)

The three core EUDR compliance obligations

Every product covered by the EUDR must meet three conditions to enter or leave the EU market:

Deforestation-free. The product must not come from land that was deforested or had forests degraded after 31 December 2020. This applies whether the deforestation was human-caused or not.
Legally produced. The product must comply with the laws of the country where it was produced — covering land rights, environmental protection, labor rights, tax, anti-corruption, and trade.
Covered by a Due Diligence Statement. The operator must file a DDS in the EU information system, including geolocation data for every plot of land involved.

A useful way to picture this: condition #1 is about what happened to the land, condition #2 is about whether the production was lawful, and condition #3 is about whether you can prove both of the above on paper.

EUDR scope: commodities, products, and exemptions

The seven commodities covered by the EUDR

Cattle · Cocoa · Coffee · Oil palm · Rubber · Soya · Wood

Examples of derived products in scope

Cattle → beef, leather, hides
Cocoa → chocolate, cocoa butter, cocoa powder
Oil palm → palm oil, glycerol, many cosmetic and food ingredients
Rubber → tyres, gloves, industrial rubber components
Soya → soya meal, soya oil, animal feed
Wood → furniture, pulp, paper, charcoal, fuelwood

What's out of EUDR scope

Goods made entirely from recycled material.
Printed products such as books, newspapers, and printed pictures — these were removed from scope by the December 2025 revision because their deforestation risk was judged minimal.
Products made before the regulation entered into force (29 June 2023) under specific transitional provisions.

The 31 December 2020 deforestation cut-off date

One date matters more than any other in the EUDR: 31 December 2020. This is the deforestation cut-off date — the line in the sand the regulation draws.

If the land your commodity was produced on was forest as of 31 December 2020 and was subsequently cleared or degraded, the resulting product is non-compliant — full stop, regardless of when it was harvested, regardless of whether the clearing was legal under the producing country's own laws.

This is why geolocation data is non-negotiable. The only way to prove a plot of land was not deforested after 31 December 2020 is to know exactly where that plot is, and then check it against satellite imagery from on or before that date. The EUDR shifts the burden of proof onto the operator: you must demonstrate deforestation-free status, not wait for an authority to prove deforestation.

EUDR deadlines: the 2026 timelines explained

Why the delays? Two recurring reasons. First, the EU's central IT system (the platform where DDSs are filed) wasn't ready in time. Second, both EU and non-EU stakeholders raised significant concerns about administrative readiness — especially smallholder farmers in producing countries.

The delay is not a softening of intent. The Council and Parliament have been clear that the core obligations remain intact. Use the extra time to prepare, not to deprioritize.

EUDR country risk classification: low, standard, high

This is one of the most practically important parts of the EUDR — and it directly determines how much work your compliance team has to do.

In April 2025, the European Commission published Implementing Regulation (EU) 2025/1093, which sorts every country in the world into one of three EUDR risk tiers based on their deforestation profile:

Low risk — 140 countries, including all EU member states. Operators sourcing from these countries get a simplified due-diligence regime: collect basic information (including geolocation), but skip the full risk-assessment and mitigation cycle in Articles 10 and 11 of the EUDR — unless you spot credible information of non-compliance.
Standard risk — most other countries. Full EUDR due diligence applies.
High risk — Belarus, Myanmar, North Korea, and Russia. Enhanced scrutiny and a higher rate of competent-authority checks.

EUDR operators vs traders: who has to do what

The December 2025 revision introduced a major simplification to the EUDR due-diligence chain. Under the original text, due diligence obligations cascaded down the supply chain. Under the revised text:

The first operator placing a product on the EU market is responsible for filing the full DDS, including geolocation data.
Downstream operators and traders simply pass on the DDS reference number. They no longer have to file their own statements.

This is a significant change. It concentrates the EUDR compliance burden at the entry point and dramatically reduces the paperwork for distributors, wholesalers, retailers, and processors further down the chain.

There are also lighter-touch rules for micro and small primary producers in low-risk countries: they can submit a one-time simplified declaration, and providing a postal address is acceptable in lieu of geolocation coordinates.

EUDR risk assessment: Articles 9, 10, and 11 explained

The EUDR's due-diligence process is built on three articles. For operators that are required to do full due diligence (i.e., not in the simplified low-risk regime), here is what each article asks of you:

Article 9 — Information collection. Gather descriptions, quantities, country of production, geolocation coordinates of every plot, supplier details, and proof of deforestation-free and legal sourcing. This is the data foundation of the entire DDS.
Article 10 — Risk assessment. Analyze the collected information against three lenses: forests and indigenous peoples (does sourcing harm forests or violate community rights?), country-of-origin risks (deforestation rates, governance, corruption, human rights), and supply chain complexity (can you trace to the specific plot of land?).
Article 11 — Risk mitigation. Where the Article 10 assessment identifies a non-negligible risk, take mitigating action: collect additional information, conduct independent audits, support supplier compliance, or — in the worst case — switch suppliers.

An EUDR risk assessment is not one-and-done. It is an ongoing process with annual reviews and updates as conditions change. Documentation must be retained for at least five years and made available to competent authorities on request.

🧠 Quick check: Your company sources cocoa from three countries — Ecuador (low risk), Côte d'Ivoire (standard risk), and a high-risk country. For which sources do you need a full Article 10/11 risk assessment? (Answer in the FAQ section.)

Filing your DDS in TRACES: the EU information system

TRACES (Trade Control and Expert System) is the European Commission's central electronic platform where every EUDR Due Diligence Statement is filed. Without a valid DDS reference number in TRACES, regulated products cannot legally cross the EU border — customs will hold the shipment.

What goes into a TRACES DDS submission:

Product description (HS code, trade name, scientific name where relevant)
Quantity (net mass, volume, or units)
Country of production and specific region
Geolocation coordinates of every plot of land
Supplier and recipient details
A formal statement that due diligence has been carried out and the deforestation/legality risk is no more than negligible

For large operators with high transaction volumes, TRACES supports an API connection so DDSs can be filed in bulk directly from internal systems. The current technical specification limits each DDS to 25 MB and a maximum of 10,000 plots — practical constraints that matter once you start scaling submissions.

How to prepare for EUDR compliance: a practical checklist

Map your supply chain. Identify which of your products fall under EUDR, and trace each one back to country of origin and (where required) plot-level geolocation.
Classify your risk exposure. Use the EU's country risk tiers to figure out where you need full due diligence and where the simplified regime applies.
Engage suppliers early. Smallholders especially need help understanding what geolocation data looks like, and why you're asking for it. Treat suppliers as partners, not data sources.
Set up your DDS workflow. Decide who in your organization is responsible for filing in TRACES, and how DDS reference numbers will flow downstream.
Document everything. Keep records of the data you collected, the risk assessments you ran, and the mitigation steps you took — for at least five years.
Track regulatory updates. The Commission's simplification review is due by 30 April 2026, and further changes are possible.
Invest in EUDR compliance software. For any company with more than a handful of suppliers, manual tracking will not scale. Look at supply-chain sustainability platforms that integrate supplier data collection, country-risk lookups, and TRACES-compatible outputs.

EUDR FAQs

When does the EUDR actually apply?

The EU Deforestation Regulation applies from 30 December 2026 for large and medium operators and traders, and from 30 June 2027 for micro and small operators. These dates were set by Regulation (EU) 2025/2650, which postponed the original December 2024 application date by two years.

What is the EUDR cut-off date for deforestation?

The EUDR cut-off date is 31 December 2020. Any product made from a covered commodity that comes from land deforested or degraded after this date cannot legally be placed on or exported from the EU market.

What is a Due Diligence Statement (DDS) under the EUDR?

A Due Diligence Statement is the electronic declaration filed in the EU's TRACES information system by the operator first placing a product on the EU market. It contains geolocation data for the plots of land where the commodity was produced and confirms the operator has carried out due diligence in line with Articles 9, 10, and 11 of the EUDR.

Which commodities are covered by the EUDR?

The EUDR covers seven commodities: cattle, cocoa, coffee, oil palm, rubber, soya, and wood. It also covers a wide range of derived products such as beef, leather, chocolate, palm oil derivatives, tyres, soya meal, furniture, pulp, and paper.

Are books still in scope of the EUDR?

No. Printed products including books, newspapers, and printed pictures were removed from EUDR scope by the December 2025 revision, because their deforestation risk was judged minimal.

What is the difference between EUDR and EUTR?

The EU Timber Regulation (EUTR) was the predecessor law, applying only to timber and timber products from 2013. The EUDR replaces it and significantly expands the scope to seven commodities including cattle, cocoa, coffee, oil palm, rubber, and soya. The EUDR also introduces stricter due diligence requirements, geolocation data, and an electronic Due Diligence Statement filed in TRACES.

What is TRACES under the EUDR?

TRACES (Trade Control and Expert System) is the European Commission's central electronic information system where operators file their EUDR Due Diligence Statements. It records the geolocation data, product information, and DDS reference numbers needed for compliance and customs clearance.

Which countries are classified as low risk under the EUDR?

Implementing Regulation (EU) 2025/1093 classifies 140 countries as low risk, including all EU member states. Four countries — Belarus, Myanmar, North Korea, and Russia — are classified as high risk. All other countries are classified as standard risk.

What are the penalties for EUDR non-compliance?

EUDR penalties are set by each EU member state and can include fines of up to 4% of EU turnover, product seizure, exclusion from public procurement and EU funding, and confiscation of revenues from non-compliant products.

Who needs to comply with the EUDR — operators or traders?

Under the December 2025 revision, the operator first placing a product on the EU market is responsible for filing the full Due Diligence Statement. Downstream operators and traders simply pass on the DDS reference number rather than filing their own statements. Micro and small primary producers in low-risk countries face simplified obligations.

Does the EUDR apply to products made before June 2023?

Generally no — the regulation contains transitional provisions for products produced before its entry into force.

Answers to the quick checks

Coffee exporter / German roaster: The German roaster is the operator (they are the one first placing the product on the EU market). The Brazilian exporter is outside the EU and is not a trader in EUDR terms — they are the supplier the German roaster must collect data from.
Cocoa from three countries: You need a full Article 10/11 risk assessment for Côte d'Ivoire (standard risk) and the high-risk country. For Ecuador (low risk), the simplified regime applies — you still collect data, but skip the heavy risk assessment unless something looks off.

EUDR: a new era of responsible sourcing

The EUDR is part of a broader generational shift in how the EU treats supply chains. The journey from voluntary conflict-mineral reporting to mandatory responsible-mineral sourcing is a useful precedent: the bar has moved from "did you ask?" to "can you prove it, with coordinates?"

Companies that treat the 2026 deadline as a paperwork exercise will struggle. Companies that use the time to genuinely understand where their commodities come from — and to build supplier relationships that make annual data collection routine — will turn EUDR compliance into a competitive advantage.

Need help with EUDR compliance?

Acquis Compliance provides EUDR compliance software and supply chain sustainability tools that help manufacturers and brands map their supply chains, classify country risks, collect supplier data through a single portal, and produce TRACES-ready Due Diligence Statements. Talk to our EUDR compliance experts →

EU Deforestation Regulation (EUDR) Compliance Guide: 2026 Deadlines, Requirements & Due Diligence

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