The EU Deforestation Regulation (EUDR) establishes binding rules for companies placing certain commodities on the EU market. Understanding the specific regulatory requirements—not just the general concept—is essential for compliance teams preparing for the December 2026 deadline.
This guide breaks down the EUDR regulations in detail: what the rules actually say, which products fall under scope, how country risk classifications work, and what recent amendments mean for your compliance obligations.
EUDR Legal Framework
The EU Deforestation Regulation (Regulation EU 2023/1115) entered into force on June 29, 2023. It replaces the earlier EU Timber Regulation and significantly expands the scope of commodities requiring deforestation-free verification.
The regulation operates on three core legal requirements:
Deforestation-free. Products must be produced on land that has not been subject to deforestation after December 31, 2020. This cut-off date is fixed—it does not roll forward as time passes.
Legal production. Products must comply with all relevant laws of the country of production, including land use rights, environmental protection, labor rights, human rights, and tax regulations.
Due diligence statement. Before placing products on the EU market, operators must submit a due diligence statement to the EU Information System confirming they have assessed and mitigated risks.
Commodities and Products in Scope
EUDR regulates seven commodity categories and all products derived from them:
Cattle: Live animals, beef, veal, offal, leather, gelatin, and other cattle-derived products.
Cocoa: Cocoa beans, cocoa paste, cocoa butter, cocoa powder, chocolate, and confectionery.
Coffee: Green coffee beans, roasted coffee, coffee extracts, and instant coffee.
Oil palm: Palm oil, palm kernel oil, and products containing palm oil (food, cosmetics, biofuels).
Rubber: Natural rubber, latex, tires, and rubber-based industrial products.
Soya: Soybeans, soybean oil, soy flour, soy protein, and animal feed containing soy.
Wood: Timber, wood products, furniture, pulp, paper, and printed materials.
The 2025 amendments removed certain printed products from scope, but the vast majority of derived products remain covered. If a product contains any of these commodities as ingredients or components, EUDR applies.
These seven commodities were selected because they drive the majority of commodity-driven deforestation worldwide. The chart below shows each category’s share of global forest loss since 2001.
Who Must Comply
EUDR creates obligations for two categories of businesses:
Operators
Operators are companies that first place covered products on the EU market (importers) or export them from the EU. Operators bear full due diligence responsibilities regardless of company size. They must collect supply chain information, assess risks, mitigate identified risks, and submit due diligence statements before products enter the market.
Traders
Traders are companies that buy or sell covered products already on the EU market. Large traders (non-SMEs) have the same obligations as operators. Small and medium enterprises have reduced obligations—they must keep records and ensure their suppliers have submitted due diligence statements, but they are not required to conduct independent risk assessments.
The 2025 amendments introduced a new category: micro and small primary operators. These businesses now only need to submit a simplified one-time declaration rather than ongoing due diligence statements.
Country Risk Classification System
EUDR uses a three-tier country risk classification that determines the level of due diligence required:
Low risk: 140 countries are classified as low risk, including all EU member states. Products from low-risk countries require simplified due diligence—operators must still collect geolocation data, but they skip the extensive risk assessment and mitigation steps.
Standard risk: Most non-EU countries fall into this category by default. Standard risk requires full due diligence: information collection, risk assessment, risk mitigation, and due diligence statement submission.
High risk: Four countries are currently classified as high risk: Belarus, Myanmar, North Korea, and Russia. Products from high-risk countries face enhanced scrutiny, higher inspection rates, and more stringent verification requirements.
The Commission will review and update country classifications regularly based on deforestation rates, enforcement capacity, and other criteria.
The country risk classification reflects deforestation severity across producing nations. The chart below ranks countries by total commodity-driven forest loss, providing context for how the EU assigns risk tiers.
Due Diligence Requirements
The regulation prescribes a specific due diligence process that operators must follow:
Information Collection
Operators must gather: product descriptions and quantities, geolocation coordinates for all production plots, harvest or production dates, supplier information, and evidence that products meet deforestation-free and legality requirements.
Geolocation data is mandatory. For plots under 4 hectares, a single GPS coordinate suffices. For larger plots, polygon boundaries mapping the plot perimeter are required. This enables satellite-based verification of whether land was forested on the cut-off date.
Risk Assessment
Using collected information, operators must assess the risk that products are linked to deforestation or illegal production. Assessment criteria include: country risk classification, complexity of the supply chain, presence of indigenous peoples or local communities, history of deforestation in the sourcing region, and reliability of supplier information.
Risk Mitigation
If risk assessment identifies concerns, operators must take mitigation measures before products can enter the market. Measures may include: additional supplier verification, independent audits, third-party certification review, or satellite-based land cover analysis to verify coordinates against deforestation data.
Due Diligence Statement
After completing the process, operators submit a due diligence statement to the EU Information System. The statement must be submitted before products are placed on the market. It confirms that due diligence has been exercised and that no more than negligible risk exists.
For step-by-step compliance guidance, see our EUDR compliance guide.
2025 Amendments and Simplifications
In December 2025, the EU adopted amendments that modify several aspects of the original regulation:
Delayed implementation. Compliance deadlines were pushed back by 12 months. Large operators must comply by December 30, 2026. SMEs have until June 30, 2027.
Simplified obligations for small operators. Micro and small primary operators (under 50 employees, under €10 million turnover related to covered products) now submit a one-time simplified declaration instead of ongoing due diligence statements.
Downstream operator simplification. Companies further down the supply chain who receive products with existing due diligence statements have reduced obligations—they can rely on upstream due diligence rather than conducting independent assessments.
Printed products excluded. Printed paper products are no longer in scope, reducing compliance burden for publishing and media industries.
Commission review. By April 30, 2026, the Commission must report on the regulation’s impact and administrative burden, particularly for smaller operators.
Enforcement and Penalties
EU member states will enforce EUDR through designated national competent authorities. Enforcement mechanisms include:
Risk-based inspections. Authorities will conduct checks based on risk profiles, with higher inspection rates for products from high-risk countries. Inspections may be unannounced.
Product seizure. Non-compliant products can be confiscated at borders or removed from the market.
Financial penalties. Fines can reach up to 4% of a company’s EU-wide annual turnover for the preceding financial year.
Market exclusion. Companies with serious or repeated violations may be temporarily or permanently banned from placing products on the EU market.
Public procurement exclusion. Non-compliant operators may be excluded from public contracts and funding.
Private parties—including NGOs and civil society organizations—can also submit substantiated concerns to competent authorities, who must then investigate.
Frequently Asked Questions
When do EUDR regulations take effect?
Large operators and traders must comply by December 30, 2026. Small and medium enterprises have until June 30, 2027. The regulation entered into force in June 2023, but compliance deadlines were delayed by 12 months in December 2025.
What is the EUDR cut-off date for deforestation?
December 31, 2020. Products must be sourced from land that was not deforested after this date. The cut-off date is fixed and does not change over time—land deforested before this date can be used for EUDR-compliant production.
How are countries classified under EUDR?
EUDR uses a three-tier system: low risk (140 countries including all EU members), standard risk (most other countries), and high risk (currently Belarus, Myanmar, North Korea, and Russia). Low-risk sourcing requires simplified due diligence; high-risk sourcing faces enhanced scrutiny.
What geolocation data is required?
For plots under 4 hectares, a single GPS coordinate is required. For larger plots, polygon coordinates mapping the plot boundaries are needed. This geolocation data enables satellite verification of deforestation status.
What are the penalties for EUDR non-compliance?
Penalties include fines up to 4% of EU-wide annual turnover, product seizure, temporary or permanent market exclusion, and exclusion from public contracts. Enforcement is conducted by national competent authorities in each EU member state.
Next Steps
EUDR regulations establish clear requirements, but implementation demands preparation. Companies should map their supply chain traceability to identify all sources of covered commodities, engage suppliers to collect required geolocation data, and establish verification processes—whether through document review or satellite-based screening—to confirm deforestation-free status before the December 2026 deadline.
