Does the EU Deforestation Regulation apply to you?

The EU Deforestation Regulation (Regulation (EU) 2023/1115) covers certain commodities and products placed on the EU market or exported from it. They must be:

• deforestation-free: not produced on land deforested, or for wood degraded, after 31 December 2020, the regulation's cut-off date;
• legal: produced in line with the laws of the country of production.

Companies prove both through due diligence before the goods are placed on the market or exported.

Seven commodities and the products made from them that are listed in Annex I of the regulation: cattle, cocoa, coffee, oil palm, rubber, soy and wood.

For example beef, chocolate, palm oil, tyres, soy meal, timber, furniture, paper and paper packaging.

Changes to the list:

• December 2025: printed products such as books and newspapers (chapter 49) removed.
• 2026: hides and leather and many rubber articles removed.
• From 30 December 2027: instant coffee, some palm-based chemicals and frozen cattle tongues added.

What counts is the customs code of each product, not its ingredients.

• 30 December 2026: medium and large companies.
• 30 June 2027: micro and small companies.
• Exception: micro and small companies keep 30 December 2026 for wood products that the old EU Timber Regulation already covered.
• 30 December 2027: products added to the scope in 2026.

Yes. Products produced before 29 June 2023, when the regulation entered into force, are not covered. For cattle, what counts is whether the animal was born before that date.

Not to be confused with the cut-off date of 31 December 2020, which is about the land: a product made in 2027 is not compliant if it comes from a plot deforested after 2020.

The operator: the company that first places a product on the EU market or exports it. That is:

• the importer, or
• for goods grown in the EU, the farmer, forest owner or other primary producer.

Lighter rules since the December 2025 amendment:

• Micro and small primary producers in low-risk countries, which includes all EU member states, can submit a one-off simplified declaration instead.
• Manufacturers that make new products from materials already covered by a statement, and traders, no longer submit statements.
• The first company after the operator keeps the statements' reference numbers.
• Companies further down the chain that are not SMEs register in the EU information system.

For each product:

• a description and the quantity;
• the country of production;
• the geolocation of every plot of land where it was produced, as a polygon for plots over 4 hectares;
• the date or period of production;
• your supplier and your customer;
• evidence that it was produced legally and is deforestation-free.

Unless all origins are low risk, you also need a documented risk assessment.

The European Commission classifies countries in three groups:

• Low risk: all EU member states, and for example the United States, China and Ghana.
• Standard risk: for example Brazil, Indonesia, Malaysia and Côte d'Ivoire.
• High risk: Russia, Belarus, Myanmar and North Korea.

For low-risk origins you still collect geolocation and submit a statement, but you do not need a full risk assessment.

No. Certification such as FSC, PEFC, RSPO or Rainforest Alliance helps you collect information, but it does not replace due diligence.

The regulation names certification only as complementary information for the risk assessment. The company placing the goods on the market remains responsible.

Each EU country sets the penalties. They include:

• fines of up to at least 4% of the company's annual turnover in the EU;
• confiscation of the products and of the revenue from them;
• temporary exclusion from public procurement.

• Norway has decided to bring the EUDR into the EEA Agreement, but it will not be in force at the start of 2027.
• Switzerland: the EUDR does not apply; the Swiss Timber Trade Ordinance still covers wood sold in Switzerland.
• Great Britain: the EUDR does not apply.

In all three cases, your customers in the EU carry the obligation. They must have your geolocation and production data by 30 December 2026, so expect their requests well before then.