EUDR explained
What is EUDR?
The EU Deforestation Regulation bans placing or exporting certain commodities — and products made from them — on the EU market unless they are proven deforestation-free, legally produced, and backed by a due diligence statement filed with the Commission.
Last reviewed: 8 September 2026
The 60-second version
- EUDR applies to cattle, cocoa, coffee, oil palm, rubber, soya, wood and products made from them, like leather, chocolate, tyres and furniture.
- The core rule: covered goods can’t be placed on the EU market or exported unless they’re deforestation-free, legally produced, and covered by a filed due diligence statement.
- “Deforestation-free” has a specific cutoff: not produced on land deforested, or wood harvested with forest degradation, after 31 December 2020. “Deforestation” itself has a precise legal meaning here: conversion of forest to agricultural use, not simply that a tree was cut.
- With one exception for legacy timber, EUDR generally doesn’t reach back before its own starting point: goods produced before 29 June 2023 fall outside it.
- Large and medium operators, and all downstream operators/traders, are in scope from 30 December 2026. Micro/small operators and natural persons generally get until 30 June 2027, except for products that were already covered by the old EU Timber Regulation, which stay on the earlier date.
- Non-compliance penalties include fines with a legal minimum ceiling of 4% of a company’s EU-wide annual turnover, confiscation of goods and revenue, and temporary market or public-procurement exclusion.
From regulation to a compliant declaration
The most important gap that catches importers out: Liability builds on every shipment from 1 January 2026, but there is no financial obligation to EU until 2027.
EUDR enters into force, repealing the old EU Timber Regulation. Goods produced before this date are generally outside its reach.
Application dates amended twice — first by Regulation (EU) 2024/3234, then substantively by Regulation (EU) 2025/2650.
The application dates ahead are fixed — large and medium operators have months, not years, left to prepare.
Large/medium operators and all downstream operators/traders come into scope.
Micro/small operators and natural persons come into scope, with exceptions for products already covered under EUTR.
Does EUDR apply to you?
Do you place covered goods on the EU market, or export them?
EUDR applies to operators (who place goods on the market or export them), downstream operators, and traders, anyone in the chain for a covered commodity or product made from it.
Are your goods covered?
EUDR covers cattle, cocoa, coffee, oil palm, rubber, soya and wood, and a wide range of products made from them. Scope is defined precisely by customs (CN) codes in the regulation’s Annex, not by commodity name alone.
What size is your business, and when did the obligation start for you?
Large/ medium businesses, and all downstream operators and traders regardless of size, are in scope from 30 December 2026. Micro and small operators and natural persons generally have until 30 June 2027 except for products that were already covered by the old EU Timber Regulation, which follow the earlier date.
This is a summary, not advice. Scope depends on your exact product’s customs code, your role in the supply chain, and your company’s size classification under EU accounting rules. Check your position against the current European Commission guidance.
What an in-scope importer has to do
1. Know your product's status.
Confirm the exact CN code, whether it falls under EUDR’s Annex I, and which application date applies to your role and company size.
2. Trace it to where it was produced.
For most goods, that means geolocation of the production plot or cattle establishment. Plot boundaries are generally required above four hectares, except for cattle, with different rules for qualifying micro/small primary operators.
3. Establish it's deforestation-free and legally produced.
The land must not have been deforested or, for wood, harvested with forest degradation after 31 December 2020. The goods must also have been produced in line with the relevant law of the country of production (land use, environmental protection, labour rights, and more).
4. Assess and, if needed, mitigate risk.
Including checking the country-risk classification. Under current EU rules, a small list of countries is high-risk, a larger list is low-risk, and everything else is standard risk.
5. File a due diligence statement.
Submitted through the Commission’s EUDR Information System before the goods are placed on the market or exported. or a simplified declaration, where the regulation’s conditions for that route are met. Filing is a record of submission, not a verdict. The system records that a statement was made; it doesn’t check or certify that the underlying facts are true.
6. Keep records for at least five years.
This is a summary, not advice. Scope depends on your exact product’s customs code, your role in the supply chain, and your company’s size classification under EU accounting rules. Check your position against the current European Commission guidance.
What's at stake if you don't comply
EUDR sets no certificate market and no per-tonne price. Under Article 25, EU Member States must set penalties that are effective, proportionate and dissuasive, including at minimum:
“4%” gets misquoted a lot as if it’s an automatic fine. It’s the minimum ceiling Member States must legislate for the maximum fine, not a fixed penalty. Actual fines depend on national law and the case.
What this means depending on your responsibilities.
If you place goods on the EU market
You carry the core obligation, due diligence, the statement, the record-keeping. Get ahead of the geolocation and country-risk work; it’s the part that takes longest to assemble.
If you’re downstream operator or trader
You’re in scope too, regardless of size, from the first application date. Your obligation depends on what you receive from upstream and what you do with it.
If you handle compliance, sustainability or supply chain
This is a cross-functional obligation, not a single-department filing. Expect to be coordinating supplier data, legal review of country-of-production law, and an internal risk decision, not just completing a form.
If you’re a customs broker or logistics partner
Your clients will be asking whether their goods are in scope, and by when. The CN-code-level scope determination and the application-date-by-company-size rule are the two questions worth being ready for.
Proposed – not yet law
What may change next
In December 2025 the European Commission proposed extending CBAM to a wider set of downstream products containing significant quantities of iron, steel or aluminium, together with anti-circumvention measures and a temporary fund for EU producers of CBAM goods.
The Council agreed its position in June 2026 and the European Parliament’s lead committee set out its position in July 2026, with a plenary vote expected in September 2026. Until that process concludes, none of it is law and none of it changes what is in scope today.
If adopted, it would pull in importers who are entirely outside CBAM as it stands.
where EvoRep fits
Know your position before the deadline sets it.
EvoRep is developing compliance workflow software for EUDR, for importers and supply-chain teams working toward the application dates above. If EUDR affects your imports or your supply chain, talk to us.
faq
Common questions.
Is EUDR the same as the old EU Timber Regulation (EUTR)?
No. EUDR repeals and replaces it, with a broader scope (seven commodities instead of just timber) and stricter due diligence requirements. Some previously-EUTR-covered products keep the earlier 30 December 2026 date rather than the later 30 June 2027 date.
What does "deforestation-free" actually mean?
Under the regulation, it means the commodity was produced on land that hasn’t been deforested since 31 December 2020, or, for wood, harvested without forest degradation since that date. “Deforestation” itself has a precise meaning here too: converting forest to agricultural use, not simply that a tree was cut. It’s a specific legal test, not a general sustainability claim.
Does EUDR apply to goods produced before the regulation existed?
Generally no with one exception. EUDR doesn’t reach back before its own entry into force on 29 June 2023, except for timber and timber products that were already covered by the old EU Timber Regulation, which follow a separate transition running through 31 December 2029.
Does filing a due diligence statement mean the EU has approved my goods?
No. The Information System records that a statement was submitted — it doesn’t verify or certify the facts in it. National authorities can still check afterward, and responsibility for what was filed stays with the operator who filed it.
Is the 4% fine automatic?
No. It’s the minimum ceiling EU Member States must set in their own penalty laws for the maximum fine on a company. Actual fines depend on national law and the specifics of the case, and can include confiscation and market exclusion alongside or instead of a fine.
Does EUDR apply to my specific product?
It depends on the exact customs (CN) code, not just the commodity name. Two products that sound similar can be in or out of scope. Check your code against the current Annex I.
When exactly do I need to comply?
Depends on your role and company size: 30 December 2026 for large/medium operators and all downstream operators/traders; 30 June 2027 for micro/small operators and natural persons, with an exception for products already covered by the old EU Timber Regulation. Re-check the date — it has moved before.
