For years, knowing where your coffee, cocoa or timber comes from was a matter of good sourcing practice. From 30 December 2026, it becomes a legal requirement, and one you’ll have to back up with evidence. Regulation (EU) 2023/1115, known as the EU Deforestation Regulation (EUDR), aims to reduce the EU’s contribution to deforestation, forest degradation, greenhouse gas emissions and global biodiversity loss. It does this by placing obligations on the companies that bring certain commodities to the EU market, or export them from it.

The Main Requirements: Deforestation-Free, Legal and Traceable

The EUDR is built around three key requirements. Products covered by the regulation must be deforestation-free, meaning they must not originate from land that was subject to deforestation after 31 December 2020. For wood products, the regulation also addresses forest degradation occurring after this date.

They must also be produced in accordance with the relevant legislation of the country of production. Finally, businesses subject to full due diligence requirements must assess and document the risks associated with their products and submit a due diligence statement through the EU Information System before placing them on the market or exporting them.

The EUDR builds on the EU Timber Regulation (EUTR), extending similar requirements to six additional commodity groups and introducing more extensive traceability and reporting obligations.

Which Products Are Covered?

The regulation covers seven commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood. Its scope also includes a wide range of products derived from these commodities, such as chocolate, roasted coffee, tyres, paper and wooden furniture.

However, not every product containing these commodities automatically falls within the regulation. Coverage is determined by specific product categories and customs classification codes listed in Annex I.

The scope has also been revised, with certain products excluded and additional items scheduled to be covered from December 2027. For example, leather, printed books and used products are among the exclusions, while soluble coffee and certain palm-oil derivatives are included under the later application date.

This makes it important for businesses to check the product classification carefully rather than relying solely on the commodity used in production.

Who Needs to Comply?

The EUDR assigns responsibilities to different participants in the supply chain. The main categories include:

• Operators – businesses placing relevant products on the EU market for the first time or exporting them.
• Micro and small primary operators – eligible smaller producers who may benefit from simplified requirements under specific conditions.
• Downstream operators – businesses processing or handling products that have already been covered by upstream due diligence.
• Traders – businesses making relevant products available on the EU market.
• Authorised representatives – entities appointed to submit due diligence statements or simplified declarations on behalf of operators.

The requirements differ depending on the company's role, size and position in the supply chain. Some businesses must conduct full due diligence, assess risks and submit statements, while others have more limited obligations, such as retaining and verifying relevant information.

Understanding which category a business falls into is therefore an important first step in preparing for compliance.

Key Dates to Keep in Mind

Following several changes to its implementation schedule, the EUDR now has a phased application timeline:

• 30 December 2026: General application for large and medium-sized operators and traders.
• 30 June 2027: Extended deadline for most micro and small operators.
• 30 December 2027: Application of the requirements to products newly added to the regulation's scope.

How Will Compliance Be Monitored?

EUDR enforcement will follow a risk-based approach, with competent authorities conducting checks to verify whether businesses meet the regulatory requirements.

These checks may involve reviewing documentation and geolocation data, using satellite monitoring and carrying out inspections at business premises or production sites. Customs authorities may also suspend the release of relevant goods while compliance is being verified.

If a company is found to be non-compliant, authorities can require corrective measures, withdraw or recall products from the market, or impose other restrictions.

Financial penalties can be substantial. For legal entities, the maximum fine must be set at a level of at least 4% of annual EU-wide turnover, although the actual penalty depends on the circumstances of the infringement. Other possible measures include confiscation of products and revenues, exclusion from public procurement and public funding, and temporary restrictions on placing products on the market in cases of serious or repeated violations.

Companies may also face reputational consequences, as final decisions against legal entities can be made publicly available.

How Can Businesses Prepare?

Preparing for the EUDR starts with understanding how the regulation applies to a company's products and supply chain. Businesses should begin by answering a few key questions:

• Which of our products fall within the scope of the regulation?
• What is our role in the supply chain?
• Do we know the geographical origin of our products and the land where the relevant commodities were produced?
• Can we obtain and maintain the documentation needed to demonstrate compliance?

The answers will help identify where changes may be needed in sourcing practices, supplier relationships, data collection and internal record-keeping.

Traceability is particularly important. Businesses must be able to link relevant products to their production areas and provide the necessary supporting information. Due diligence records must also be retained for the required period, while relevant reference numbers and information need to be communicated to other supply chain participants where applicable.

Starting this work early gives companies more time to identify information gaps, engage with suppliers and establish reliable processes before the applicable deadlines.

Want the essentials without digging through the full regulation?

Register on the COVERE² platform and download the EUDR one-pager for free. It gives you a concise overview of the regulation, the key dates, the obligations for each role and what enforcement looks like, so you can see what the EUDR means for your business and start preparing early.

Register on the platform and download the EUDR one-pager to get started