The EUDR bars cattle, cocoa, coffee, oil palm, rubber, soya and wood products from the EU market unless they are deforestation-free after the 31 December 2020 cut-off, legally produced, and covered by a due diligence statement.
Obligations apply from 30 December 2026 for medium and large companies, from 30 June 2027 for micro and small operators, and from 30 December 2027 for products added to Annex I in 2026.
The company that first places the product on the EU market, or exports it, carries the due diligence; downstream operators and traders keep supplier and customer records and the reference numbers they receive.
The plot geolocations and supplier records that due diligence demands are the same inputs a company needs to measure land-use-change emissions under the GHG Protocol Land Sector and Removals Guidance, so both workstreams share one data foundation (Terrascope analysis).
| Regulator | The European Commission (Directorate-General for Environment) runs the Information System, classifies country risk and issues guidance; each Member State's competent authorities carry out checks and enforce penalties |
| Instrument | Regulation (EU) 2023/1115, as amended by Regulation (EU) 2024/3234 (date of application) and Regulation (EU) 2025/2650 (simplification); product list in Annex I as amended by Commission Delegated Regulation (EU) 2026/2102 |
| Who is in scope | Operators: any company that places a relevant product on the EU market for the first time or exports it. Downstream operators and traders: record-keeping duties only. Micro or small primary operators in low-risk countries: a one-time simplified declaration |
| Estimated population | 275,000 unique importing operators (Commission estimate from customs data, May 2026); domestic producers and downstream companies sit on top of that figure |
| Application date | 30 December 2026 for medium and large companies and for timber products; 30 June 2027 for micro and small operators established by 31 December 2024; 30 December 2027 for products added in 2026 (soluble coffee, frozen cattle tongues, additional palm oil derivatives) |
| Core obligation | Products must be deforestation-free (no deforestation after 31 December 2020), produced under the laws of the country of production, and covered by a due diligence statement submitted before placing on the market or export |
| Checks by authorities | Annual checks cover at least 3 percent of operators sourcing from standard-risk countries, 9 percent of operators and 9 percent of product quantity from high-risk countries, and 1 percent from low-risk countries |
| Penalty regime | Set by each Member State; fines with a maximum of at least 4 percent of EU-wide annual turnover, confiscation of products and revenues, exclusion from public procurement for up to 12 months, and a temporary ban on placing products on the market |
The European Union applies Regulation (EU) 2023/1115, the EU Deforestation Regulation (EUDR), from 30 December 2026 to every company that places cattle, cocoa, coffee, oil palm, rubber, soya or wood products on the EU market or exports them, after Regulation (EU) 2025/2650 of 19 December 2025 postponed the start by a year and simplified the obligations. Each operator files a due diligence statement in the Commission's Information System, backed by the geolocation of every plot the commodity came from, before the product moves. Alongside the Corporate Sustainability Reporting Directive, it is the second EU instrument that reaches food and agriculture supply chains at plot level, and non-EU producers meet it the moment their goods cross the EU border.
The EU has regulated illegally harvested timber since 2013, extended the model to six agricultural commodities in 2023, and then spent two years adjusting the start date and the obligations.
2013, the EU Timber Regulation. Regulation (EU) No 995/2010 required timber operators to run a due diligence system. It is repealed on 30 December 2026 and continues to apply until 31 December 2029 to timber produced before 29 June 2023.
2023, the EUDR. Regulation (EU) 2023/1115 entered into force on 29 June 2023 with an original application date of 30 December 2024.
2024, first postponement. Regulation (EU) 2024/3234 moved the date to 30 December 2025.
2025, postponement and simplification. Regulation (EU) 2025/2650 moved the date to 30 December 2026, created the downstream operator category with no statement of its own, introduced the one-time simplified declaration for micro or small primary operators, removed printed books from scope, and set the fine benchmark at 4 percent of EU-wide turnover.
2026, product scope. Delegated Regulation (EU) 2026/2102, published 17 September 2026, removed cattle hides and leather, most retreaded tyres, vulcanised rubber articles, soya beans for sowing, and aircraft and vehicle seats, and added soluble coffee, frozen cattle tongues and additional palm oil derivatives from 30 December 2027.
An operator proves three things for every relevant product before placing it on the EU market or exporting it: the product is deforestation-free, it was produced legally, and a due diligence statement covers it.
Deforestation-free (Article 3(a)): the commodities come from land that stayed free of conversion from forest to agricultural use after 31 December 2020, and wood was harvested without forest degradation after that date. Forest means land over 0.5 hectares with trees above 5 metres and canopy cover above 10 percent; agricultural plantations are excluded.
Legally produced (Article 3(b)): the commodities comply with the laws of the country of production on land use rights, environmental protection, forest rules, labour and human rights, free, prior and informed consent of Indigenous Peoples, and tax, anti-corruption, trade and customs rules.
Due diligence statement (Article 3(c)): the operator collects the Article 9 information, runs the Article 10 risk assessment, applies Article 11 risk mitigation, and submits a statement in the Information System declaring that no or only a negligible risk was found. Statements are kept for five years.
Information requirements (Article 9): product description and quantity, country of production, the geolocation of every plot where the commodity was produced (polygons above four hectares) with the date or time range of production, supplier and customer details, and evidence of deforestation-free and legal production. Any deforestation on a plot disqualifies every commodity from that plot.
Due diligence system (Article 12): operators keep a documented system, review it annually, and companies above SME size publish an annual report on it, which they can fold into reporting under other EU value chain laws.
Operators sourcing only from low-risk countries skip the risk assessment and mitigation steps under Article 13, after checking the chain for mixing and circumvention. The Commission's 22 May 2025 benchmarking list classifies most countries as low risk, names Belarus, Myanmar, North Korea and Russia as high risk, and leaves every other country, including Brazil, Indonesia, Malaysia, Côte d'Ivoire and Ghana, at standard risk.
The regulation reaches every company from the plot to the EU shelf, with the weight of the obligation on whoever first places the product on the EU market or exports it. Micro and small operators established by 31 December 2024 have until 30 June 2027, except for timber products already covered by the Timber Regulation.
Operators
Any natural or legal person who, in the course of a commercial activity, places a relevant product on the EU market for the first time or exports it. Operators run full due diligence and submit the statement. A non-EU company becomes an operator when it places products on the EU market itself; otherwise its EU importer is the operator and asks it for the plot data.
Downstream operators and traders
A downstream operator makes or sells products from relevant products already covered by a statement or simplified declaration; a trader makes relevant products available further down the chain. Both keep supplier and customer details for five years and, where the supplier is an operator, the reference numbers of that operator's statements. Companies above SME size register in the Information System and, on a substantiated concern, verify that due diligence was exercised before selling on. The amended Article 5 removes the duty on both categories to submit their own statement.
Micro or small primary operators
A natural person or micro or small undertaking in a low-risk country that places on the market or exports commodities it grew, harvested or raised itself submits a one-time simplified declaration, receives a declaration identifier, and can give a postal address in place of geolocation. Where a Member State database already holds the Annex III information, the declaration is waived.
Supply-chain reach (Terrascope analysis): the geolocation duty falls on the operator, so it flows upstream as a data request to every farm, plantation, cooperative and mill supplying an EU importer. Cocoa from Côte d'Ivoire and Ghana, palm oil from Indonesia and Malaysia, soya and cattle from Brazil, coffee from Vietnam and Colombia, and rubber from Thailand enter the EU with plot coordinates attached as a condition of entry. EU consumer goods groups, food manufacturers and retailers are the operators for most of that volume.
| Milestone | Date | What applies |
| EU Timber Regulation (current regime for wood) | 3 March 2013 | Due diligence for timber operators, repealed 30 December 2026 |
| EUDR enters into force | 29 June 2023 | Cut-off date for deforestation fixed at 31 December 2020 |
| Information System opens | 4 December 2024 | Registration and due diligence statements |
| Country benchmarking list published | 23 May 2025 | Low-risk and high-risk lists; all other countries standard risk |
| Regulation (EU) 2025/2650 published | 23 December 2025 | Downstream operator category, simplified declaration, 4 percent fine benchmark |
| Delegated Regulation (EU) 2026/2102 in force | 18 September 2026 | Amended Annex I product list |
| EUDR applies: medium and large companies, timber products | 30 December 2026 | Due diligence statements required |
| EUDR applies: micro and small operators | 30 June 2027 | Full obligations for micro and small operators established by 31 December 2024 |
| Newly added products in scope | 30 December 2027 | Soluble coffee, frozen cattle tongues, additional palm oil derivatives |
| Customs single window interface | 1 December 2029 | Reference numbers exchanged between customs and the Information System |
| General review | 30 June 2030 | Commission report on extending scope to other ecosystems, other commodities and financial institutions |
Timber produced before 29 June 2023 stays under the Timber Regulation until 31 December 2029.
1. Supply-chain ripple into producer countries. The Commission's implementation page states that non-EU producers have no direct obligations and will be asked for the locations where products were grown, harvested or raised. An exporter in Indonesia, Brazil, Ghana or Vietnam keeps its EU buyers from 30 December 2026 by supplying polygon coordinates for every plot above four hectares. EU buyers collect that data through a supplier engagement programme.
2. One data foundation for the EUDR, CSRD and FLAG targets. Article 12(3) lets companies reporting under other EU value chain laws fold the EUDR report into that reporting, and a company in scope of the Corporate Sustainability Reporting Directive already discloses Scope 3 by category under ESRS E1-8. The plot geolocations and production dates collected for EUDR due diligence are the inputs for land-use-change emissions under the GHG Protocol Land Sector and Removals Guidance and for Science Based Targets initiative Forest, Land and Agriculture (FLAG) targets. A company that treats EUDR data as a compliance record only collects it twice (Terrascope analysis).
3. Scope keeps moving. The 2026 delegated act shows the product list is a live document. The 2030 review reconsiders leather and assesses extending the rule to grasslands, peatlands and wetlands, to further commodities including maize, and to financial institutions.
The first due diligence statements are due before goods move on 30 December 2026, and the plot-level data behind them is the slowest part to assemble.
Map your products to Annex I. Check every product code against the amended Annex I, including the 2027 additions, and identify where your company is the operator and where it is a downstream operator or trader. A food manufacturer is often both.
Collect plot geolocations from suppliers now. Every plot needs coordinates to six decimal places, polygons above four hectares, and a production date or time range. Cooperatives and mills that aggregate smallholder volumes need every contributing plot, because one deforested plot disqualifies the whole lot.
Build the due diligence system as an audit trail. Articles 10(4) and 11(3) require operators to document and review risk assessments and mitigation decisions annually and to show competent authorities how each conclusion was reached. Companies above SME size appoint a compliance officer at management level and an independent audit function.
Reuse the data for land-use-change emissions. The plot records that prove no deforestation after 31 December 2020 also quantify land-use-change emissions in Scope 3 category 1 under the GHG Protocol Land Sector and Removals Guidance and for FLAG targets. Design the supplier data request once, for both uses (Terrascope analysis).
An EUDR due diligence system a competent authority can check follows the same discipline as a greenhouse gas inventory prepared for assurance: documented sources, reviewed decisions, and a trail from supplier record to reported figure. Download Your First Climate Audit: A Practical Guide for a step-by-step walkthrough of what reviewers ask for.
Terrascope's AI-powered platform helps food, agriculture and consumer goods companies turn supplier and plot data into audit-ready disclosures and targets, including TSE Group, the Indonesian palm oil company with a public no-deforestation commitment, which measured land use change, palm oil mill effluent and fertiliser emissions across five business units and separated FLAG from non-FLAG emissions in line with the GHG Protocol Land Sector and Removals Standard.
Scope 1, 2, and 3 emissions measurement. Integrations pull supplier, purchase and production data from your source systems monthly, so the commodity volumes and origins in your EUDR due diligence file and in your Scope 3 inventory come from one record.
Audit-ready reporting. Audit Trail makes every figure traceable from supplier record to disclosure, with reviewer access built in, so the annual Article 12 system review and the assurance engagement on your inventory draw on the same evidence.
Supply-chain intelligence. Analytics shows which commodities, origins and suppliers carry your land-use-change emissions, so supplier engagement targets the plots that matter for deforestation risk and FLAG reductions alike.
Multi-framework alignment. ISSB Reporting drafts your climate disclosures from measured data, reviewed by your team, with ESRS E1, IFRS S2 and FLAG target reporting built from the same inventory.
Are you ready to get ahead of the EU Deforestation Regulation's due diligence requirements? Speak to a Terrascope expert and see how we help companies move from supplier and plot data to audit-ready disclosures and FLAG targets.