Regulation (EU) 2023/1115 on deforestation-free products, EUDR for short, is intended to prevent goods for which forest was cleared or degraded from entering the EU market. It entered into force as early as 2023, but its date of application was postponed twice. Under amending Regulation (EU) 2025/2650 of December 2025, the obligations apply to large and medium-sized undertakings from 30 December 2026 and to most micro and small undertakings from 30 June 2027. At the same time, the obligations were considerably simplified.
The shifted reference date for size classification is important here. What now counts is the situation as at 31 December 2024. As a result, undertakings previously regarded as small may have to be classified as medium-sized and be fully subject to the obligations from 30 December 2026.
Which products are covered
Seven commodities are covered, namely cattle, cocoa, coffee, oil palm, rubber, soya and wood, together with products made from them such as beef, chocolate, palm oil, tyres, furniture, paper and packaging. Books and printed matter of Chapter 49 were removed entirely by the 2025 amendment; paper and paperboard of Chapter 48 remain covered. Exactly which products are meant is set out in Annex I of the Regulation by reference to commodity codes. As with the Carbon Border Adjustment Mechanism (CBAM), tariff classification therefore decides whether a product is covered. Otherwise the two sets of rules have little in common. CBAM requires emissions data and certificates, the EUDR proof of origin down to the plot of land.
Annex I is being amended. The Commission adopted a delegated act on 13 July 2026, the two-month objection period for Parliament and Council has expired, and entry into force is expected for December 2026. Products to be removed include cattle hides and leather, retreaded tyres, soya beans for sowing, certain articles of vulcanised rubber, conveyor and transmission belts, and seats for aircraft and vehicles. Products to be added are soluble coffee, certain palm oil derivatives and frozen bovine tongues. Newly added products are covered only from 30 December 2027.
What deforestation-free means
A product may only be placed on the market, made available or exported if three conditions are met:
- Deforestation-free: The commodities come from land that has not been deforested after 31 December 2020. In the case of wood, there must also have been no forest degradation there since then.
- Legally produced: Production complies with the laws of the country of production, for example on land use, environmental protection and labour law.
- Due diligence statement: A due diligence statement exists for the product.
Operators and traders
The main burden lies with the operator who places a product on the EU market for the first time or exports it, typically the importer. It must collect information, assess the risk, mitigate it where necessary and submit a due diligence statement in the EU information system before import.
Since the 2025 amendment, the principle of a single statement essentially applies. A distinction must be made here. The first downstream operator no longer submits its own due diligence statement, but must document the reference numbers of the original statement and traceability. Further down the chain it is sufficient to keep the supplier information and cooperate with the authorities; there is no longer any separate duty to check. The details are set out in the Commission guidelines of May 2026 and should be examined in each individual case.
Geolocation and risk assessment
The core of the due diligence obligation is geolocation data. For each plot of land on which the commodities were produced, coordinates must be provided, for larger plots as a polygon. For micro and small primary operators from low-risk countries, simplified declarations have been introduced which are submitted once and allow postal addresses instead of geographic coordinates. On this basis, the operator assesses whether there is a more than negligible risk that the product is not deforestation-free or not legal. If so, it must obtain further evidence or do without the goods.
How thoroughly to check also depends on the country benchmarking. In May 2025 the Commission classified all countries into the categories low, standard and high risk. Parliament rejected the classification in July 2025, but the vote was not binding and the list continues to apply. A first review based on updated data is planned for 2026, so classifications may change.
Where the risk is low, only risk assessment and risk mitigation are dropped. The information requirements and the due diligence statement remain, and any risk of circumvention or mixing must still be excluded. It is therefore not an exemption. Products from high-risk countries are checked more frequently.
The role of customs
On import and export, the reference number of the due diligence statement must be stated in the customs declaration. Customs carries out risk-based checks and cooperates with the competent authorities. In Germany, under the draft German implementing act, these are the federal states (Länder) for domestic primary production and timber harvesting, and the Federal Office for Agriculture and Food (Bundesanstalt für Landwirtschaft und Ernährung, BLE) for everything else. Where there is a suspicion, customs can suspend the release of the goods. If the reference number is missing, the goods are not cleared.
Penalties
Member States must lay down effective penalties. The Regulation requires that the maximum amount of fines can reach at least 4 per cent of the annual EU-wide turnover. In addition, there is confiscation of the products and of the revenues, and exclusion from public procurement.
The German implementing act goes further. The draft adopted by the Federal Cabinet on 14 August 2026 provides not only for fines of up to EUR 100,000 and, for large undertakings, up to 4 per cent of Union turnover, but also for criminal offences. It provides for imprisonment of up to five years, in particularly serious cases from one to ten years, and in cases of recklessness up to three years. Documentation and procedural infringements are also covered, not only substantive errors. The legislative procedure is scheduled to be completed before 30 December 2026.
How to proceed
- Check whether you are affected. Compare your commodity codes with Annex I, including the forthcoming amendments.
- Clarify size and deadline. Check your classification as at 31 December 2024. This determines whether your obligations start on 30 December 2026 or only on 30 June 2027.
- Clarify your role. Are you an operator, a first downstream operator or further down the chain? Your obligations depend on this.
- Request data. Include geolocation data and evidence of legality in your supply contracts; suppliers need lead time.
- Adapt the customs process. Make sure that the reference number is available in time and that your freight forwarder states it in the declaration.
- Assign responsibility. Designate internally who submits and documents the due diligence statements. When assessing supply chains, advice in the individual case can be useful, see Compliance.