EU Deforestation Regulation (EUDR) at a glance

Summary - EUDR at a glance

The EU Deforestation Regulation (EUDR/VO 2023/1115) replaces the previous EU Timber Regulation (EUTR) and goes much further: it obliges companies to fulfill a comprehensive due diligence obligation before placing seven raw materials on the market. Specifically affected are wood, cocoa, coffee, soy, palm oil, cattle and rubber as well as all products made from them. Large companies must fully implement the regulations from December 2026. Small and medium-sized companies will not be affected by the regulation until July 2027. The three-stage process comprises information collection, risk assessment and risk mitigation, with transparency and traceability back to the cultivation area being crucial.

The regulation defines deforestation as the conversion of forests into agricultural land, regardless of whether it is caused by humans or not. The cut-off date is December 31, 2020: products may not originate from areas that have been deforested or damaged since then. The EUDR sets out clear responsibilities, not only in relation to deforestation, but also with regard to fair working conditions, human rights and, in particular, the rights of indigenous peoples.

Companies need to analyze their supply chains, clarify responsibilities, record geodata correctly and keep a constant eye on legal developments. Although the regulation entails additional work, it also offers real opportunities: those who act early can build sustainable supply chains, strengthen long-term partnerships and position themselves better in a competitive environment.

Update: What has changed with the EUDR (as at February 2026)

The thrust remains the same: deforestation-free, legally compliant supply chains. But a lot has changed in three areas:

New deadlines: The application of the EUDR has been postponed further.

• Medium & large companies: from December 30, 2026
• Micro & small enterprises: from June 30, 2027
• Special case: Micro & small enterprises that were already covered by the previous timber trade regulations (EUTR) will start from December 30, 2026.

Relief for downstream players: In future, only the first distributor, i.e. the company that makes goods available on the EU market for the first time, will submit the due diligence statement (DDS) in the EU system. Downstream market participants and traders are exempt from this. Instead, they must record and store the relevant reference and identification numbers as well as supply chain information and submit them on request. Because downstream players predominantly work with DDS reference numbers, the time-consuming multiple recording of identical data is also eliminated. This saves time and reduces sources of error.

Country benchmarking: Countries are officially divided into risk categories (low/standard/high). This has a direct impact on the depth of checks and the effort involved and should be taken into account in the procurement strategy and supplier management.

The core remains unchanged: cut-off date 31.12.2020, legal production in the country of production and the three-stage due diligence process: collect information, assess risk, mitigate risk.

The EU Deforestation Regulation(EUDR): Definition, objectives & importance

What is the EUDR and why was it introduced?

The EU Deforestation Regulation(EUDR/VO 2023/1115) is the EU's response to a problem that is no longer far away: Deforestation and forest degradation are directly linked to global supply chains and therefore also to products that are traded, processed and consumed in Europe every day. The regulation obliges companies to prove that certain raw materials and products are deforestation-free and have been produced in the country of origin in accordance with the law. This is the EUDR definition of forest.

The focus is on seven raw materials that are particularly relevant for deforestation risks according to EU logic: Cattle, cocoa, coffee, palm oil, soy, wood and rubber. This also includes products made from these raw materials (e.g. furniture, leather, chocolate, depending on the customs/product categories specified in the regulation).

The Deforestation Ordinance is based on a clear triad of due diligence obligations:

• Collect information (including supply chain, suppliers, product data and, above all, geolocation data on the cultivation/production area),
• Assess risk (incl. country and context factors),
• Reduce risk (if the risk is not negligible).

Background and development of the regulation

The Deforestation Regulation is not a quick fix, but the result of a political process lasting several years: Following the Commission's draft in November 2021 and the political agreement in December 2022, the Regulation formally came into force on June 29, 2023. The distinction between entry into force and application is crucial for companies. The latter was adjusted in December 2024 and again in December 2025 to make the introduction more feasible without abandoning the basic logic.

The current schedule (as of February 2026) is as follows:

• Large & medium-sized enterprises: Application from December 30, 2026
• Micro & small enterprises: Application from June 30, 2027
• Special case: micro/small enterprises that were already covered under the previous EU Timber Trade Logic (EUTR): December 30, 2026

At the same time, the EU has introduced targeted simplifications to avoid unnecessary duplication of work in the supply chain. One example is the due diligence statement: In principle, it should now only be submitted by the company that places the goods on the EU market for the first time.

Importance of the EUDR for environmental and climate protection

The EUDR is more than just another compliance project: it directly links environmental and climate protection with market rules. Forests are not only a source of raw materials, but also a carbon sink, a sanctuary for biodiversity and the livelihoods of many communities. Deforestation destroys ecosystems and exacerbates climate change in equal measure.

The Deforestation Regulation is intended to ensure that only products that have not been associated with deforestation since December 31, 2020 are traded in the EU. In addition, the products must have been legally produced in the country of origin, including the environmental and human rights requirements applicable there.

The bottom line is that the regulation creates a new minimum standard. Anyone who wants to take action in the EU must not only be aware of deforestation risks, but also prove, manage and document them.

Objectives of the EUDR

Reducing global deforestation through responsible sourcing

The EUDR pursues a clear objective: deforestation and forest degradation should no longer be bought. To achieve this, the regulation relies on a principle that is particularly effective in practice: market access only for deforestation-free products. This turns responsible procurement from a best-practice issue into a concrete expectation for companies. Reliable evidence, good data and reliable suppliers are the basic prerequisites for this.

The objective behind this can be summarized in three points:

• Reduce deforestation pressure: Where the EU market sets clear requirements, incentives are provided to organize production without deforestation.
• Making risk supply chains visible: Lack of transparency is becoming a bottleneck - shifting priorities towards reliable data and clean origins.
• Strengthening responsibility along the supply chain: Risks should not be passed on, but actively managed, from procurement to market access.

Promotion of sustainable agricultural practices

In addition to forest protection, the EUDR is also changing how agricultural supply chains will function in the future. The EU market is redefining what is considered deliverable and is therefore incentivizing more sustainable practices because they are more economically viable. Those who produce in a traceable manner, document cleanly and reduce risks will secure access to European supply chains.

In practice, this means that sustainability becomes more measurable, supplier development more important and short-term sourcing less attractive. Overall, the EUDR shifts the understanding of sustainability away from pure voluntary commitments towards an implementation that works in purchasing, quality management and cooperation with suppliers in the long term.

Contribution to achieving the EU climate targets

Forests are climate stabilizers. If deforestation is reduced, carbon reservoirs are preserved, emissions are avoided and biodiversity is protected. For companies, the climate impact is particularly noticeable in two areas:

• Climate risks become supply chain risks: deforestation not only jeopardizes the environment, but also availability, prices and reputation.
• Evidence becomes crucial: The regulation makes politically set climate targets partially verifiable via supply chain logic.

The EUDR is therefore not just a forest protection rule, but a building block for making climate policy effective along global supply chains.

Sustainable development as a cross-cutting objective

The EUDR makes it clear that sustainability is more than just green. It is not just about forest protection, but also about ensuring that supply chains are legally clean and social standards are adhered to, precisely because deforestation is often associated with land conflicts, unresolved rights and poor working conditions in practice. In practice, the regulation aims to achieve three things:

• Responsible procurement as standard, not as an add-on
• Better safeguarding of supply chains through clear requirements
• Greater credibility vis-à-vis the market, stakeholders and regulators

Obligations for companies

Introduction of due diligence obligations and risk assessments

In everyday life, the EUDR means above all that companies must set up their purchasing in such a way that deforestation and legal risks are identified at an early stage and reduced where necessary. This requires a due diligence system that really works, not just as a document, but in the purchasing, quality, compliance and IT processes.

Since the adjustment at the end of 2025, it is particularly important to clearly define the roles in the supply chain: As a rule, the company that places the goods on the market in the EU for the first time issues the due diligence declaration (DDS). Downstream actors use this declaration as a reference. Nevertheless, the responsibility for ensuring that one's own processes run smoothly remains; no one can sit back and relax completely.

It is fundamentally important that all steps in the supply chain are traceable. This is the EUDR basic requirement - complete traceability.

Requirements for the traceability of products

Traceability is the backbone of the Deforestation Ordinance. It is understood in much more concrete terms than traditional batch or supplier verification. It is crucial that a product can be traced back to the area on which the raw material was produced. To achieve this, companies must record the relevant information in such a way that it can be processed in the EU information system as part of the due diligence declaration.

What is particularly important in practice:

• Geolocation at plot level: The due diligence declaration specifies the geographical coordinates of the plots of land on which the raw materials were produced.
• Point or polygon, depending on the area: For smaller areas, a single point may be sufficient in certain cases. Otherwise, polygons are used to accurately map the cultivation or production area.
• Technical format & upload capability: Manual input is hardly realistic for many areas. The system therefore supports the upload of geodata (e.g. via GeoJSON), which entails requirements in terms of data format, structure and quality.
• Temporal reference of production: In addition to where, the when is also relevant. This means that the deforestation-related audit can be reliably linked to the production period.

Checking supply chains for deforestation risks

The regulation does not require a guarantee of "zero risk". However, it does require companies to assess and manage risks in such a way that ultimately only goods are traded where the risk is negligible or has been reduced accordingly through measures. EU instruments such as country benchmarking help with this, but are no substitute for the company's own risk assessment.

What the risk assessment typically boils down to:

• Structured assessment of risk drivers: country/regional risk (benchmarking), complexity of the supply chain, known hotspots, governance/legal enforcement, and plausibility of supplier data and area data.
• Think deforestation assessment in terms of area: In practice, much boils down to an area check, i.e. the question of whether and when forest loss/deforestation has taken place on the specified area. This is often supported by satellite/monitoring data and plausibility checks.
• Risk mitigation as "tangible" measures: If risks are not negligible, concrete steps such as additional evidence, tighter supplier requirements, independent audits, monitoring, segmentation of goods flows or, if necessary, the realignment of sourcing decisions are required.

EUDR in the customs process: What must be included in the declaration?

In practice, EUDR compliance is not only decided in the audit folder, but often very specifically at customs: certain information must be provided in the customs declaration for the import or export of EUDR-relevant goods, otherwise the goods will not be released.

Important: The goods will only be released if the coding is complete (incl. reference number). If something is missing, the import/export cannot be processed in case of doubt.

Reporting and documentation obligations

EUDR compliance does not work without proper documentation. Companies must be able to show how they arrived at their decisions. This requires two things: firstly, evidence that really stands up to scrutiny, and secondly, a reliable process that creates and updates these documents on an ongoing basis and makes them easy to find.

Three levels are central to this:

• Documentation of due diligence: Companies must be able to prove what information was available, how risks were assessed and what measures, if any, were implemented, including the respective responsible parties and approvals.
• Retention and evidence management: Evidence is not "nice to have", but must be retrievable for years, precisely because audits can take place at different times. In practice, this is less of a legal issue and more of a data and process issue.
• Annual public reporting (for certain companies): For non-small companies, publishing an annual report on the due diligence system is a recurring mandatory item that should be planned into governance and reporting structures at an early stage. Ideally in such a way that it is consistent with existing sustainability and compliance reporting.

In practice, it is helpful to treat documentation obligations not as a filing problem, but as a design issue:

• What minimum proof must be provided for each product flow?
• Where are they stored in the system?
• How do you prevent different teams from working with different versions?
• And how can it be shown at the touch of a button that a process has been released in compliance with EUDR?

For many companies, the EU information system becomes the linchpin here, because due diligence statements are created and managed there, including references that are used further down the chain.

Cooperation with suppliers to comply with the EUDR

No company fulfills the deforestation ordinance on its own. The crucial information almost always originates within the company's own organization. This is precisely why cooperation with suppliers is becoming an important success factor: not as a communication measure, but as a structured, contractually and procedurally secured data exchange. And yes: in many supply chains, these are de facto dependencies, without data there is no trade.

Since the simplifications, it is even more important that cooperation in the supply chain is properly organized. If the DDS lies with the first distributor and others work primarily with references, the supplier data really must be correct. This is the only way to ensure that reference numbers, batches and internal approvals match and nothing gets lost along the way. Attention should be paid to this with batches, deliveries and the DDS.

Many underestimate that the deforestation regulation not only affects legal and purchasing, but also data and systems. The EU information system is the central working platform for due diligence declarations and references. If you define clear responsibilities early on and structure the data properly (for uploads such as GeoJSON, for example), you will save a lot of effort later on and make far fewer mistakes.

Country benchmarking

With country benchmarking, the EU has created a central instrument to systematically classify the deforestation risk per country of origin. Since May 22, 2025, an official classification has been available for the first time, which divides countries into three categories: low risk, standard risk and high risk. Benchmarking is therefore a decisive lever for the question of how deep due diligence must go - and where companies can work with simplified requirements.

The logic of the classification is important here: the EU publishes explicit lists for low risk and high risk. All countries that are not explicitly on these lists are automatically classified as standard risk. This makes "standard" the basic category - and the risk classification determines how extensive risk analysis and risk mitigation must be in practice. This applies to country benchmarking in detail.

Risk categories at a glance

Low risk: Countries in this category are considered to be at comparatively low risk of deforestation-related violations. Companies in this category benefit from simplified due diligence obligations: Information collection remains mandatory, a comprehensive risk assessment and risk mitigation is generally not required. Typical examples (excerpt) include

• Many EU member states (classified as low risk) and the USA
• as well as individual countries that often seem surprising but are explicitly listed as low risk (e.g. Laos or the Dominican Republic)

Standard risk: This category is the "default" classification: It applies to all countries that are not explicitly listed as low or high. For imports from standard risk countries, the full due diligence obligations of the EUDR continue to apply, including risk assessment and, if necessary, risk mitigation measures.

High risk: Countries in this category are subject to particularly strict expectations, not only because of the full due diligence requirements, but also because they are accompanied by a higher level of regulatory scrutiny. In the first official classification, only four countries were listed as high risk:

• Belarus
• Myanmar
• North Korea
• Russia

EUDR-relevant products and raw materials

List of raw materials concerned (e.g. wood, soy, palm oil)

For the EUDR (Regulation EU 2023/1115), the most important thing is how the raw material is legally classified. The decisive factor is whether it belongs to the relevant raw materials and whether the specific product is listed in Annex I. The goods concerned are defined there via CN/customs tariff codes, in some cases only for certain subgroups ("ex" codes). This applies to HS codes and TARIC codes according to the EUDR.

The Deforestation Ordinance is linked to seven raw materials:

• Wood
• Soy
• Palm oil
• Beef
• Cocoa
• Coffee
• Rubber (natural rubber)

Important in practice: As soon as a product contains one of these raw materials, was fed with it or was manufactured from it, it is worth taking a look at Annex I. Only if the product category is explicitly listed there does it fall within the scope. Composite products are also affected by the EUDR - this applies to composite products.

Product groups and their specific requirements

The regulation does not work with sectors, but with product groups via customs tariff codes. This may seem cumbersome at first glance, but it provides clarity: one and the same material can be in scope or out of scope depending on its classification, which is precisely why correct tariff classification (CN code) is a key step in any EUDR analysis.

What has changed recently: In the course of the targeted revision, Annex I was technically adapted, among other things by removing certain printed products from the scope (Annex I adjustment "ex 49").

Exceptions and special regulations

In addition to the principle of Annex I decisions, there are a number of special cases in the EU Deforestation Regulation and the accompanying Guidance/FAQ that are regularly overlooked in projects.

Important exceptions and delimitations include:

• Purely recycled products (100% recycled): Products made entirely from recycled material are generally not subject to EUDR. However, as soon as virgin material is mixed in, the exception may not apply.
• Waste, used or second-hand products: Certain second-hand products that have completed their life cycle and would otherwise be disposed of as waste are excluded.
• Packaging if it only "runs along": Packaging materials or containers that are used exclusively as packaging for another product (transportation/protection function) are typically out of scope. The situation may be different if packaging is traded as an independent product.
• Since the revision at the end of 2025, many printed products under Chapter/HS 49 have also been excluded from the EUDR scope of application.
• Samples or specimens for testing or analysis: Product samples of negligible value (e.g. for testing/analysis) are excluded.

In practice, these special cases often lead to misclassifications. Here are the most important distinctions.

• EUDR & packaging, instructions and displays: when does what apply?
• Correspondence vs. advertising material (letters, brochures, flyers)
• Used goods under EUDR (e.g. tires, pallets)
• Bamboo & cardboard packaging: classification and typical stumbling blocks
• EUDR for paper products and disposable aprons

Affected companies & timetable

Scope of application according to company size and activity

Whether a company falls under the EUDR depends less on the sector and more on its role in the flow of goods. The regulation makes a rough distinction between "operators" and "traders". Since the amendment at the end of 2025, an additional distinction has been made between initial distributors, traders and downstream market participants:

• First distributor / exporter: Anyone who places a relevant product on the EU market for the first time or exports it from the EU typically falls into the operator role.
• Trader: Anyone who resells or makes available a relevant product after it has already been placed in the EU is considered a trader.
• Downstream operator (new): Companies that place on the market/export relevant products in the course of a commercial activity that are already covered by a DDS or simplified declaration. Their obligations are - according to the amendment - essentially the same as for traders: no DDS levy, but information/recording obligations (and registration obligation for non-SMEs).

These are the due diligence obligations for market participants and traders in detail.

Transition periods and timetable for implementation

One point in particular is crucial for the timetable today: although the regulation has been in force since 2023, it will only become mandatory from the application deadlines. Following the amendments in December 2024 and December 2025, the current timetable (as of February 2026) is as follows

• Large and medium-sized companies (large/medium operators): from December 30, 2026
• Micro and small enterprises (micro/small operators): from June 30, 2027
• Special rule for "EUTR products": For market participants who were established as such on 31.12.2024, the later start date of 30.06.2027 generally applies - except for products that fall under the Annex to Regulation (EU) No. 995/2010 (EUTR). Here the application already applies from 30.12.2026.

EUDR and the cut-off date: Find out how to deal with goods in stock and later placing on the market here.

Differences between large companies and SMEs

The regulation deliberately differentiates between company size and role. Large and medium-sized companies usually have to fulfill more formal obligations. SMEs are relieved in some cases. This applies in particular where the rules are intended to prevent the same work being done more than once in the supply chain. These thresholds apply in detail to corporations and SMEs.

This is typically more significant for large and medium-sized companies:

• More formal governance and more transparency: For non-SMEs, for example, this includes a fixed mandatory date each year - a public report on the due diligence system. In addition, companies must review their system internally on an annual basis.
• Greater expectation of systematics and scalability: Large organizations must set up due diligence in such a way that it functions consistently across product groups, countries and business units, including audit capability.

Where SMEs are typically relieved:

• Less reporting burden: SMEs do not always have the same public reporting obligations as non-SMEs.
• Simplifications along the chain: The obligation to submit the due diligence statement (DDS) lies in principle with the initial distributor. Downstream players should no longer have to submit DDSs in the same way. The idea of first downstream is particularly relevant here: Only the first downstream entity must record and maintain references in a structured manner, instead of this obligation running endlessly through the supply chain.

Monitoring compliance with the EUDR

Competent authorities and monitoring mechanisms

The EU relies on the member states to enforce the EUDR. Each state appoints its own authorities to monitor the rules and enforce them on a day-to-day basis. Control is therefore not carried out centrally from Brussels, but locally, ideally with uniform standards and closely interlinked with customs and market surveillance.

The checks are risk-based. Depending on the risk category of the country of origin, authorities must carry out a minimum number of checks: at least 1% for low risk, 3% for standard risk and 9% for high risk. For companies, this means that the chance of an inspection depends heavily on the origin of the raw materials or product. Therefore, data, evidence and internal decisions must be fully and comprehensibly documented at all times.

Carrying out inspections and audits

Checks under the EUDR are more than just paperwork. Authorities check whether the information is comprehensible and whether the internal assessments are really conclusive. They also check whether the processes in the company are set up in such a way that the rules are actually complied with in the end. This can happen on an ad hoc basis, for example in the event of indications or anomalies, and there are also regular checks within the framework of the specified minimum quotas.

In practice, an inspection usually consists of several parts. Authorities compare documents, carry out plausibility checks and look particularly closely at information on origin and geodata. There are often spot checks that are examined in greater depth. Depending on the case, on-site measures are also possible. If a risk is acute, authorities can also intervene immediately and temporarily stop the flow of goods, for example by securing goods or temporarily suspending the placing on the market or export.

Role of digital systems for monitoring

The EUDR can hardly be implemented without a digital infrastructure. This is why the EU information system plays a central role. Due diligence declarations are recorded and managed there and can be reused in the supply chain. Downstream companies can refer to existing entries by adopting the reference and verification numbers, either manually or via a CSV upload.

Technical scaling is also provided for large volumes of data: The system supports a machine connection via an API to manage declarations and data records in bulk. This makes the system a central access point for the authorities: it facilitates targeted screening, supports risk-based selection decisions and creates a uniform basis on which checks can be documented in a comprehensible and repeatable manner. There are also user guides that describe how to use the system in practice.

Challenges & opportunities

Effects on importers and exporters

For importers and exporters, the EUDR is primarily changing trade. Trade is increasingly becoming a question of data capability and process stability. Anyone moving flows of goods into or out of the EU must adjust to the fact that deliverability no longer just means price, quality and availability, but also reliable evidence along the flow of goods. This has a direct impact on contract design, supplier portfolios, procurement strategies and logistics, especially where supply chains have previously worked with intermediaries, mixed flows or incomplete documentation.

In practice, risk management is also shifting as a result. Goods from complex regions of origin are more frequently only procured if data, geo-information and proof of legality are available in sufficient quality. At the same time, there is increasing pressure to standardize information flows in such a way that they also work with large volumes (keyword: digital interfaces, structured data uploads and consistent references).

The trade policy dimension should also not be underestimated. Several trading partners have criticized the EUDR in international forums as a potential barrier to trade. While this debate does not automatically lead to a weakening of the requirements, it is an indication that EUDR compliance will be a permanent factor in trade relations, negotiations and market access discussions in the future.

Challenges for developing countries

For many supplier countries, it is not so much the aim of the EUDR regulation that is the problem, but its implementation in everyday life. Especially where millions of small farmers produce in small-scale structures, there is often a lack of resources and infrastructure. Collecting geodata, documenting digitally, registering farms and maintaining data on an ongoing basis costs time and money. Small cooperatives, local exporters and individual producers are often unable to do this without support. This concern is particularly evident in countries such as Côte d'Ivoire. Smaller cocoa companies there say that the costs and organizational effort can quickly threaten their existence, while large corporations usually find it easier to cope with such requirements.

Indonesia also repeatedly points out that small farmers in particular can quickly fall out of EU supply chains without digital infrastructure or reliable internet. Not because they automatically produce less, but because they are often unable to provide the required proof in the short term.

This creates a risk that comes up again and again in the discussion. If implementation is not designed to be inclusive, large, data-rich companies in particular could end up benefiting, while smaller providers are forced out of the market. This is why support for producer countries is so important. Technical assistance, funding and practical support are needed to ensure that the EUDR really works in international trade.

Opportunities for sustainable trade practices

As demanding as the requirements are: The EUDR also opens up a new opportunity for international trade, namely competition based on verifiable sustainability. Where intransparency can still create a price advantage today, in the long term this will shift towards supply chains that can demonstrate data quality, legality and stable partnerships. This is exactly the kind of level playing field that makes sustainable practices more economically attractive, especially in industries where deforestation risks have been difficult to quantify.

In addition, the EU is increasingly supporting implementation through cooperation and support formats. One example is the "Team Europe Initiative" on deforestation-free value chains, which is supported by the European Commission and aims to strengthen partnerships with producer countries and facilitate the transition to deforestation-free supply chains. Such programs are a signal that the EUDR is not only understood as a control instrument, but also as an impetus for investment, capacity building and more resilient supply relationships.

And finally, the EUDR has an impact beyond the EU. It sets a standard to which other markets, buyers and financing logics can orient themselves. In the medium term, this could mean that deforestation-free and legal supply chains are not just "EU compliance", but a global reference point - with positive effects for companies that make structured investments early on and for producing regions that can demonstrably scale sustainable production.

Conclusion

The EUDR marks a significant step towards greater sustainability and environmental protection and at the same time presents companies with specific requirements. Anyone placing relevant products on the EU market must check and adapt supply chains, ensure transparency and fully document the origin of raw materials. The regulation thus makes it clear that deforestation-free production is not an add-on, but an integral part of day-to-day business.

The targeted use of modern technologies plays a decisive role in this. Digital tools and a reliable database enable companies to make processes more efficient, identify risks at an early stage and systematically meet compliance requirements.

Those who consistently implement the regulation not only fulfill their legal obligations, but also position themselves as a reliable partner in sustainable supply chains in the long term. This is not only a contribution to the protection of forests, but also a real competitive advantage.