EUDR: Deforestation due diligence for your supply chain

For most companies 30 December 2026: Following amendments in December 2024 and December 2025, the entry into application is now: large and medium operators by 30 December 2026; micro and small operators by 30 June 2027; and micro and small operators already covered by the EU Timber Regulation by 30 December 2026. Link to European Commission official website: https://green-forum.ec.europa.eu/nature-and-biodiversity/deforestation-regulation-implementation_en

You need the geographical coordinates of the plots of land where the commodity was produced. For plots under 4 hectares, a single latitude/longitude point is sufficient. For larger plots, you need a polygon — a set of coordinates outlining the boundary of the production area.

Coordinates must be in decimal degrees format of at least 6-digits following the order latitude, longitude (e.g. 53.857048, 16.989015; caution: GeoJSON requires first longitude, then latitude). This data must be traceable back to the specific production plot — not just a region or country. The EU system (TRACES) only accepts GeoJSON data with a maximum size of 25 MB (approximately 1,000,000 vertices) per DDS submission. GeoJSON files must use the WGS84 (EPSG:4326) coordinate reference system, with coordinates expressed in decimal degrees.

Books, newspapers, and printed products (HS code 4901) will be removed from Annex I and will no longer be subject to EUDR requirements in the future. Passing on due diligence statement numbers along the supply chain will be significantly reduced: Only the first buyer is required to collect the numbers. Downstream non-SMEs must still register in TRACES, but are not required to create or pass on their own DDS. However, if there are justified concerns, an obligation to review upstream due diligence statements applies. Requirements for legality evidence will be simplified: Previously, under the EUTR, all legal requirements of lawful forestry had to be verified — in future, only evidence relevant to deforestation will be required. Trade with low-risk countries: Small and micro primary producers from low-risk countries are exempt from the due diligence statement obligation. Instead, a one-time simplified declaration via the EU information system with an identification number will suffice. EU agricultural and forestry enterprises: The obligation to submit a due diligence statement is dropped; instead, a one-time simplified declaration via the EU information system with an identification number is required. This declaration covers: name and address, relevant commodity or product, trade name, a one-time estimated annual quantity with a percentage deviation, country of production, geolocation or postal address, and a declaration of due diligence compliance. State of negotiations: The Multi-Stakeholder Platform met on 10 February 2026. The Commission is working on implementing acts — a delegated act on Annex I is planned for March 2026, including an opportunity for public feedback.

This is the single biggest operational challenge of EUDR.

Practical approaches: (1) Send structured questionnaires; (2) Use satellite-based tools; (3) Work with cooperatives; (4) For wood, use sawmill intake records.

The regulation does not accept "we couldn't get the data" as an excuse.

Yes. You must submit a due diligence statement to the EU Information System before placing a covered product on the EU market.

The statement includes: company details, product description, commodity type, country of production, geolocation data. You receive a reference number that must accompany the product through the supply chain.

Penalties are severe. Fines up to 4% of annual EU turnover. Plus: product seizures, exclusion from public procurement, temporary bans, permanent trade bans for repeat offenders.

Authorities will use satellite monitoring and risk-based targeting.

Geolocation requirements generally apply regardless of country of origin.

However, the risk level differs. EU countries are likely classified as low risk = simplified due diligence. Moreover, planned simplifications of the EUDR possibly may include micro or small primary operators (MSPOs) to submit a one-time simplified declaration, and the geolocation requirement can be replaced by the postal address of the plots of land or establishment.

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Seven commodity groups are in scope: cattle, cocoa, coffee, oil palm, rubber, soy, and wood — plus their derived products. This includes a wide range of downstream goods: leather, chocolate, furniture, paper, tyres, cosmetics containing palm oil, and many more.

The full list of covered products is defined in Annex I of the regulation, mapped to CN (Combined Nomenclature) codes. If your product contains, was fed with, or was made using any of these commodities, it falls within scope. The key obligation: you must prove the commodity was produced on land that was not deforested after 31 December 2020.

The updated FAQ confirms that samples for testing or evaluation are excluded from the EUDR, as these usually have negligible value and may be consumed or destroyed in the course of analysis.

Norway, Iceland, Liechtenstein, and Switzerland are members of EFTA, a trade group separate from the EU. This means they are treated as "third countries" under the EUDR — in other words, they are subject to the same rules as any non-EU country. Norway, Iceland, and Liechtenstein are also part of the European Economic Area (EEA), which gives them access to the EU's single market. The EU has flagged the EUDR as potentially relevant for the EEA, which means these three countries are currently examining whether to adopt it. However, this process is lengthy and complex, and can take several years. Until and unless they formally adopt it, they remain third countries under the EUDR. Switzerland is a special case: it is an EFTA member but never joined the EEA. As a result, there is no adoption process to consider — the EUDR applies to Switzerland and Swiss companies in exactly the same way as it does to any other non-EU country. In short: All four countries are currently treated as third countries under the EUDR. Norway, Iceland, and Liechtenstein might adopt the regulation in the future, but this is uncertain and will take time. Switzerland will remain a third country regardless.

The Commission clarified in the FAQ that traceability is necessary to demonstrate that there has been no deforestation at the specific location of production. Traceability requirements apply to each batch of imported/exported/traded relevant commodities. However, for products passing a "bulk phase", such as soy or palm oil, but also pulp, wood chips or large sawmill operations, this means that the operator needs to ensure that all possible plots of land involved in a shipment are identified and that the commodities are not mixed at any step.