EUDR: the complete guide to the EU Deforestation Regulation (2026 update)

This guide is for general information and is not legal advice.

The EU Deforestation Regulation (EUDR), Regulation (EU) 2023/1115, is an EU law on products linked to deforestation. It applies from 30 December 2026. From that date, companies may only sell certain products in the EU, or export them from the EU, if they can show that the products did not come from land deforested after 31 December 2020 and were produced in line with the laws of the country of production.

The EU adopted the regulation because agricultural expansion is the main cause of deforestation worldwide, and the EU imports large volumes of the commodities involved. The FAO estimates that 10.9 million hectares of forest were lost each year between 2015 and 2025 ^[1].

This guide covers the rules as of 22 October 2026: which products are covered, which companies have obligations, what due diligence involves, how the due diligence statement and geolocation requirements work, how countries are classified by risk, penalties and deadlines. It is for EU companies with obligations under the regulation and for producers outside the EU who supply them.

EUDR at a glance

If you sell cattle, cocoa, coffee, palm oil, rubber, soya or wood, or products made from them, into or out of the EU, you must be able to show they come from land that hasn't been deforested since the end of 2020 and that they were produced legally. The company that first brings the product onto the EU market carries the main duty and files a due diligence statement before the goods move. The rules apply from 30 December 2026. The key facts are below.

How The Landbanking Group can help

The Landbanking Group offers two tools relevant to the EUDR.

Start with Landler Pathfinder. Pathfinder is our free screening tool. Put your sites, sourcing regions and markets on a map, and its compliance screener shows which nature-related rules, including the EUDR, could apply to you, why, and what evidence they require. Try Pathfinder.

Screen your plots on Landler. For companies with plot data, Landler screens mapped plots for detected forest-cover loss against the 31 December 2020 cut-off using satellite imagery and global forest change data, and helps teams review flagged plots and identify likely drivers. Results are screening evidence: they help you decide where to look further and support your wider due diligence. They are not a legal compliance determination on their own. Talk to our team about a compliance plan.

Where the EUDR stands now

Has the EUDR been delayed?

Yes, twice, by a year each time. The regulation originally applied from 30 December 2024. Regulation (EU) 2024/3234 moved that to 30 December 2025. Regulation (EU) 2025/2650, which entered into force on 26 December 2025, moved it again to 30 December 2026, with 30 June 2027 for most micro and small operators ^[3].

The second amendment did more than change the date. It created a new downstream operator role, removed the duty for downstream companies to file their own statements, and introduced a one-off simplified declaration for the smallest producers in low-risk countries. It also required the Commission to carry out a simplification review by 30 April 2026.

What happened in 2026

• 4 May: the Commission published its simplification review (COM(2026) 191). It concluded that further amendments to the regulation are not appropriate, and estimated that the simplifications made since 2024 cut annual compliance costs by about 75% compared with the original text ^[4].
• End of June: the EU Information System, where due diligence statements are filed, reopened after technical updates.
• 13 July: the Commission adopted a delegated act changing the product list, an implementing act on the Information System (Implementing Regulation (EU) 2026/1565), and a new formal guidance document ^[5][6][7].
• 21 August: a revised version 5 of the Commission's FAQ was published. One answer changed with real consequences for processors (see roles below) ^[8].
• 10 September: the Commission proposed removing French Guiana, an outermost region of the EU, from the regulation's territorial scope (COM(2026) 661) ^[9].
• 18 September: the new product list (Delegated Regulation (EU) 2026/2102) entered into force after neither Parliament nor Council objected ^[5].
• October: Member States are finalising national enforcement laws. In Germany, the implementing act had its first reading in the Bundestag on 8 October ^[10].

Will the EUDR be delayed again?

Companies should plan on the basis that it will not. Some Member States, the United States and Canada are pushing for lighter rules, and both previous postponements were agreed in December, shortly before the deadline. A third postponement can't be ruled out completely. But the Commission has said it will not propose further changes, the simplification package is complete, and no proposal to move the dates has been tabled. Another delay would need a new regulation agreed by Parliament and Council in a matter of weeks. Goods ordered now for delivery in January will need a due diligence statement.

EUDR deadlines

What the EUDR requires: three conditions

Under Article 3 of the regulation, a relevant commodity or product may only be placed on the EU market, made available on it or exported from it if all three of these conditions are met ^[2]:

1. It is deforestation-free.
2. It was produced in accordance with the relevant legislation of the country of production.
3. It is covered by a due diligence statement (or, for the smallest producers in low-risk countries, a simplified declaration).

If any one condition fails, the product cannot enter or leave the EU market. There are no tolerances and no minimum quantity below which the rules stop applying ^[8].

Condition 1: deforestation-free

A product is deforestation-free if the commodities it contains, was fed with or was made from were produced on land that has not been subject to deforestation after 31 December 2020. For wood there is a second test: the timber must have been harvested without causing forest degradation after that date ^[2].

Two points are often misunderstood:

• Legal deforestation still counts. Clearing land with a valid national permit does not make the commodity deforestation-free. The EUDR sets its own standard on top of local law.
• The cause doesn't matter. Deforestation means converting forest to agricultural use, whether or not it was human-induced. Land cleared by fire after 2020 and then planted with soy or used for grazing fails the test.

Condition 2: produced legally

The commodity must comply with the laws of the country where it was produced. The regulation lists eight areas of law that count ^[2]:

1. Land use rights
2. Environmental protection
3. Forest-related rules, including forest management and biodiversity conservation, where directly related to wood harvesting
4. Third parties' rights
5. Labour rights
6. Human rights protected under international law
7. Free, prior and informed consent (FPIC), including as set out in the UN Declaration on the Rights of Indigenous Peoples
8. Tax, anti-corruption, trade and customs regulations

The evidence has to be "adequately conclusive and verifiable". In practice that means land titles or use rights, permits, and documents showing compliance with labour and environmental rules. The Commission plans to set up a repository by December 2026 where producing countries can list their relevant legislation ^[6].

Condition 3: a due diligence statement

Before placing goods on the market or exporting them, the operator files a due diligence statement in the EU Information System. By filing it, the operator confirms it has carried out due diligence and found no risk, or only negligible risk, that the goods are non-compliant. It also takes legal responsibility for that conclusion ^[2]. How due diligence works and what goes into the statement are covered below.

Key definitions

These definitions from the regulation determine what is in scope ^[2]:

• Forest: land of more than 0.5 hectares with trees higher than 5 metres and a canopy cover of more than 10%, or trees able to reach those thresholds in situ. Land predominantly under agricultural or urban use is excluded.
• Agricultural plantation: land with tree stands in agricultural production systems, such as fruit orchards, oil palm plantations, olive groves and agroforestry systems where crops grow under tree cover. Agricultural plantations are not forest, so replanting an existing cocoa or oil palm plantation is not deforestation.
• Deforestation: the conversion of forest to agricultural use, whether human-induced or not.
• Forest degradation (relevant for wood): structural changes to forest cover in the form of converting primary or naturally regenerating forest into plantation forest or other wooded land, or converting primary forest into planted forest.
• Plot of land: land within a single real-estate property, as recognised by the law of the country of production, with conditions homogeneous enough to assess deforestation risk as a whole. If deforestation occurred on any part of a plot after 2020, commodities from that plot are not deforestation-free.
• Negligible risk: after a full assessment (and, where needed, mitigation), the products show no cause for concern about being non-compliant ^[6].
• Placing on the market: making a product available on the EU market for the first time. Making available means any later supply, for payment or free of charge.
• Date of production: usually the harvest date. For cattle it is the date the animal was born ^[6]. So beef from cattle born before 29 June 2023 is out of scope.

Which products are covered?

The EUDR covers seven commodities and the products listed in Annex I of the regulation, identified by their customs (HS/CN) codes. Annex I was last amended by Delegated Regulation (EU) 2026/2102, in force since 18 September 2026 ^[5].

The September 2026 amendment also confirmed that several categories fall outside the scope ^[5]:

• Samples used for testing or analysis
• Waste
• Used and second-hand products
• Packing material used only to support, protect or carry another product (pallets or crates placed on the market as products in their own right are still covered)
• Products used to manufacture medicinal products

Printed matter such as books and newspapers was taken out by the December 2025 amendment. Pulp and paper made from bamboo or recovered paper is also excluded.

Who has to comply?

The EUDR assigns duties by role, not by sector. The same company can hold different roles for different products, or even for the same product at different steps ^[8].

Operators

The operator carries the core duty. Usually it is the importer that brings a commodity into the EU, but it is also any EU producer that sells its own commodities: an EU cattle farmer, a forest owner selling timber, or a soy grower. Exporters of relevant products from the EU are operators too.

If the company that places the goods on the EU market is established outside the EU, the first company established in the EU that makes them available is treated as the operator ^[2]. Consumers are never operators, even when named as importer on a customs declaration. In online sales, the operator is the business that supplies the goods ^[8].

Non-SME operators must also report publicly every year on their due diligence system ^[2].

Micro or small primary operators

This category was created in December 2025. It covers natural persons and micro or small businesses that are established in a country classified as low risk and place on the market or export products they grew, harvested or raised themselves in that country. Instead of a statement per shipment, they submit a one-off simplified declaration, updated when needed. They may give a postal address instead of geolocation coordinates, provided it corresponds to the actual plot or establishment rather than an administrative seat ^[8].

All 27 EU Member States are classified as low risk, so this mainly helps small EU farmers and forest owners, plus small producers in other low-risk countries who sell directly into the EU.

Downstream operators and traders

Since the December 2025 amendment, companies further down the chain no longer file their own statements or repeat the due diligence. Instead they must ^[8]:

• Collect the name, postal address, email address and, where available, website of their direct suppliers and customers before making goods available
• If they buy directly from an operator, keep the operator's statement reference numbers (the operator must pass them on)
• Keep these records for five years and hand them to authorities on request
• If they are not SMEs, register in the Information System and, where there are substantiated concerns about a product, check it before passing it on and inform the authorities

The August 2026 FAQ changed one rule for processors. Any change of customs code now makes a processor a downstream operator, even when the first four digits stay the same. A coffee roaster, for example, was treated as a trader under the previous FAQ version and is now a downstream operator ^[8].

Service providers

Freight forwarders, warehouses and contract processors have no due diligence duty as long as they don't place goods on the market or export them themselves. Customs representatives, including indirect representatives, are never operators. They declare their principal's codes and reference numbers ^[8].

Company size

Size classes follow the EU Accounting Directive. A company is in a class if it does not exceed two of the three thresholds ^[11]:

Member States may raise the small-company thresholds to €7.5 million and €15 million.

Four examples

• A German coffee importer buys green coffee from Brazil. It is the operator: it does full due diligence (Brazil is standard risk), files a statement before customs clearance, and passes the reference number to the roaster it sells to.
• The roaster turns green coffee into roasted coffee, which changes the customs code. It is a downstream operator. It keeps the importer's reference number and its supplier and customer records, and registers in the Information System if it is not an SME.
• A supermarket chain sells the roasted coffee. It is a trader. It keeps supplier and customer records, but doesn't need the reference number because it didn't buy directly from the operator.
• A cooperative in Côte d'Ivoire sells cocoa to an exporter in Abidjan. Neither has EUDR duties of their own, but the EU importer that buys from the exporter cannot file its statement without the cooperative's plot geolocations and legality evidence. In practice, the importer needs data that only the cooperative and its farmers have.

How EUDR due diligence works

Due diligence has three steps: collect information, assess risk, and mitigate risk where needed ^[2]. Only once the risk is negligible can the operator file its statement.

Step 1: collect information (Article 9)

For each product, the operator must collect and keep for five years:

1. A product description, including the trade name and type, and for wood the common and full scientific species name
2. The quantity, in kilograms of net mass and, where applicable, supplementary units
3. The country of production and, where relevant, the region
4. The geolocation of every plot of land where the commodity was produced (for cattle, every establishment where the animals were kept), plus the date or time range of production
5. The name, postal address and email of the supplier
6. The name, postal address and email of the customer
7. Adequately conclusive and verifiable information that the products are deforestation-free
8. Adequately conclusive and verifiable information that production complied with the relevant legislation of the country of production

Step 2: assess the risk (Article 10)

The operator then analyses the information and decides whether there is a non-negligible risk that the products are non-compliant. The regulation lists the criteria to consider ^[2]:

• The country's risk classification
• The presence of forests in the country or area of production
• The presence of indigenous peoples, consultation and cooperation with them in good faith, and any duly reasoned claims they have over the land
• How common deforestation or forest degradation is in the area
• The source, reliability and validity of the information collected
• Concerns about the country, such as corruption, falsified documents or data, weak law enforcement, human rights violations, armed conflict or sanctions
• The complexity of the supply chain and how hard it is to trace products to the plot
• The risk of circumvention or mixing with products of unknown origin
• Conclusions of Commission expert group meetings
• Substantiated concerns and any history of non-compliance by suppliers
• Any other information pointing to a risk
• Complementary information from certification or third-party verification schemes

The list is not exhaustive ^[6]. If any criterion shows a non-negligible risk that can't be mitigated, the product cannot be placed on the market or exported. Risk assessments must be documented and reviewed at least once a year.

The Commission provides a global map of forest types on the cut-off date of 31 December 2020, at 10-metre resolution, distinguishing primary, naturally regenerating and planted forest. It is a useful first check but not legally binding ^[8]. Operators remain responsible for the conclusion.

Step 3: mitigate the risk (Article 11)

Where the risk is more than negligible, the operator must reduce it to negligible before going ahead. Measures can include asking for more information or documents, independent surveys or audits, and supporting suppliers, especially smallholders, through capacity building and investment ^[2].

Non-SME operators must also have adequate policies and controls in place: risk management, reporting and record-keeping, a compliance officer at management level and, where appropriate, an independent audit function.

Simplified due diligence for low-risk countries (Article 13)

If every commodity in a product comes from countries or regions classified as low risk, the operator can skip steps 2 and 3. It still has to collect all the Article 9 information, including geolocation, and be able to show there is no risk of circumvention or mixing with products from higher-risk countries. If it learns of a risk, full due diligence applies again ^[2].

Certification does not replace due diligence

Certification and third-party verification schemes such as FSC, PEFC, RSPO or Rainforest Alliance can provide useful information, including geolocation data, for the risk assessment. But they cannot replace due diligence. In the Commission's words, using such schemes "does not imply a 'green lane'", and the operator remains liable ^[6]. Schemes are still adapting their standards to the EUDR; PEFC, for example, published dedicated EUDR due diligence requirements in October 2026.

No mass balance

The EUDR requires traceability to the plot. Mass balance systems, which mix compliant material with material of unknown origin and track only volumes, are not accepted ^[8]. If compliant and non-compliant goods are mixed and can't be separated, the whole shipment is non-compliant. Supply chains for palm oil, soy and cocoa that rely on mass balance need to move to segregation or identity preservation for EU-bound volumes.

The due diligence statement and the Information System

Statements are filed in the EUDR Information System, which is built on the EU's TRACES platform. Companies register once and can then submit statements through the web interface or an API ^[7].

A due diligence statement contains ^[2]:

• The operator's name, address and, for goods crossing the border, its EORI number
• The HS code, a description and the quantity of the product
• The country of production and the geolocation of all plots
• Reference numbers of any existing statements the product builds on
• A declaration that due diligence was carried out and no or only negligible risk was found

After submission the system issues a reference number and a verification number. The reference number must be included in the customs declaration when goods are imported or exported, and passed to direct customers who are downstream operators or traders ^[8]. Since July 2026, the system has also assigned each statement a risk status based on risk criteria, which helps authorities target their checks ^[7].

Customs rules to note:

• Micro and small operators importing or exporting between 30 December 2026 and 29 June 2027 use an exemption code (Y141) in the customs declaration instead of a reference number.
• Downstream operators exporting goods bought in the EU don't give a reference number. They use a dedicated TARIC code ^[8].
• On re-import, the importer is an operator unless it can show the goods were previously placed on the EU market and exported.

The Commission is running online training sessions on the Information System through October 2026. Companies that haven't registered and run a test submission should do so before December.

Country benchmarking: low, standard and high risk

Every country is classified as low, standard or high risk of producing commodities that are not deforestation-free. The first list was adopted on 22 May 2025 in Implementing Regulation (EU) 2025/1093 ^[13]:

• High risk: Belarus, Myanmar, North Korea and Russia
• Low risk: about 140 countries, including all EU Member States, the UK, the US, Canada, China, India, Vietnam and Australia
• Standard risk: all others, including major producers such as Brazil, Indonesia, Malaysia and Côte d'Ivoire

The classification is based mainly on FAO data on deforestation rates, agricultural expansion for the seven commodities and production trends.

Low risk doesn't mean no obligations. Operators still need geolocation for every plot and still file statements; only the risk assessment and mitigation steps fall away. The Commission rejected calls for a "zero risk" category that would have exempted some countries entirely ^[4].

In July 2025 the European Parliament passed a non-binding resolution objecting to the classification. It had no legal effect, and the list remains in force ^[14]. A first review of the list was foreseen for 2026, using the FAO's 2025 forest data. At the time of writing, no revised list has been adopted.

Enforcement and penalties

Each Member State designates competent authorities to enforce the EUDR. They must carry out risk-based checks on a minimum share of operators each year (see the table above), can act on substantiated concerns raised by anyone, and can take interim measures such as suspending products from the market while checks run ^[2].

Penalties are set nationally but must be "effective, proportionate and dissuasive". The regulation requires at least the following to be available ^[2]:

1. Fines proportionate to the environmental damage and the value of the products. For companies, the maximum fine must be at least 4% of total annual EU-wide turnover, and higher where needed to remove the economic benefit of the breach
2. Confiscation of the products concerned
3. Confiscation of revenues from transactions involving them
4. Exclusion for up to 12 months from public procurement and from access to public funding
5. A temporary ban on placing, making available or exporting relevant products, for serious or repeated breaches
6. A ban on using simplified due diligence, for serious or repeated breaches

The Commission publishes the names of companies with final judgments against them, along with the infringement and the penalty.

Criminal liability. Under the EU Environmental Crime Directive, placing products on the market in breach of the EUDR's prohibition is a criminal offence when committed intentionally, except where it concerns a negligible quantity. Member States must provide maximum prison sentences of at least five years for individuals, and maximum fines of at least 5% of worldwide turnover or €40 million for companies ^[15]. The directive had to be written into national law by 21 May 2026, but transposition across Member States is uneven.

Germany as an example. The draft German implementing act names the Federal Office for Agriculture and Food (BLE) as the competent authority, with state authorities responsible for domestic farmers and forest owners. It provides for prison sentences of up to five years (up to ten for severe, long-lasting environmental damage), fines of up to €100,000, and fines of up to 4% of EU-wide turnover for larger companies. It is still before the Bundestag and due to enter into force on 30 December 2026 ^[10]. National laws decide penalties and inspection powers, but they cannot change the obligations themselves, which apply directly from the regulation.

EUDR vs EUTR: what changes for timber

The EUDR replaces the EU Timber Regulation, which has applied since 2013. The EUTR is repealed with effect from 30 December 2026.

The transition depends on when the timber was harvested and when it is placed on the market ^[6]:

• Harvested before 29 June 2023: EUTR rules continue to apply until 31 December 2029 for products covered by the EUTR annex. From 31 December 2029, such timber must comply with the EUDR.
• Harvested between 29 June 2023 and 30 December 2026: EUTR rules apply if placed on the market before 30 December 2026. EUDR rules apply if placed on the market from that date.
• Harvested from 30 December 2026: EUDR rules apply.

Small timber operators get no extra time: micro and small operators placing timber products already covered by the EUTR must comply from 30 December 2026.

What the EUDR means for producers outside the EU

If you grow, raise or harvest a relevant commodity outside the EU and sell it to a cooperative, exporter or trader, the EUDR places no legal duty on you. It applies to whoever places the product on the EU market ^[16].

However, the EU company that buys your product cannot file its statement without information that only you have: where your plots are, when the commodity was produced, and evidence that the land wasn't deforested after 2020 and is farmed legally. Expect buyers to ask for:

• Plot geolocation: a GPS point for plots of up to four hectares, a polygon for larger ones, and the location of every establishment where cattle were kept
• Production dates: harvest dates, or birth dates for cattle
• Land rights evidence: titles, leases, customary or communal use rights, or other documents showing the right to use the land
• Legal compliance: permits, labour and tax records, and evidence of FPIC where indigenous peoples or local communities have claims
• Segregation: proof that EU-bound volumes are kept separate from produce of unknown origin

Many producing countries are building national traceability systems to help: the Commission counts more than 60 government-led initiatives in at least 25 producer countries ^[4]. Cooperatives can collect and hold geolocation data on behalf of their members, and an EU-established cooperative can submit simplified declarations as its members' authorised representative ^[8].

Small producers in low-risk countries who export directly to the EU can use the one-off simplified declaration described above.

How the EUDR fits with other EU rules

The EUDR sets conditions for placing individual products on the EU market. Other EU laws and frameworks apply to the same supply chains, and the same plot and supplier data can be used for several of them:

• Corporate Sustainability Reporting Directive (CSRD): company-level reporting. Deforestation exposure is relevant to the biodiversity and ecosystems standard (ESRS E4).
• Corporate Sustainability Due Diligence Directive (CSDDD): company-level due diligence on human rights and environmental impacts across the value chain. It doesn't replace the EUDR's product-level checks.
• Forced Labour Regulation (EU) 2024/3015: bans products made with forced labour from the EU market from 14 December 2027. The Commission plans guidance on forced labour risks that will be relevant to EUDR supply chains ^[6].
• Empowering Consumers for the Green Transition Directive (EU) 2024/825: applies from 27 September 2026 and tightens the rules on environmental claims. Complying with the EUDR is a legal requirement, not a marketing claim. Labels such as "deforestation-free" need evidence that matches the claim.
• TNFD: the voluntary nature disclosure framework. EUDR geolocation data is a strong starting point for its "Locate" step.

What is still open

• Country benchmarking review. A first review using new FAO data was foreseen for 2026. A revised list could move countries between tiers and change who can use simplified due diligence.
• French Guiana. The Commission's proposal to exclude it from the scope (COM(2026) 661) is going through the legislative process ^[9].
• National enforcement laws. Penalties and inspection powers depend on national acts, several of which are still being adopted.
• Political pressure. Calls for further simplification continue, especially for low-risk countries. No legislative proposal has been made.
• The 2030 review. By 30 June 2030 the Commission must review the regulation, including possible extension to other wooded land and other natural ecosystems such as grasslands, peatlands and wetlands, to further commodities such as maize, to products such as biofuels, and to the role of financial institutions ^[2].

EUDR readiness checklist

Steps to take before the application date:

1. Map your products against Annex I using eight-digit CN codes, including the September 2026 changes.
2. Define your role for each product and flow: operator, downstream operator or trader, and your size class on 31 December 2024.
3. Register in the EU Information System and run a test submission in the acceptance environment.
4. Map your supply chain to the plot. Identify which suppliers can provide geolocation, production dates and legality evidence, and which can't.
5. Collect and validate geolocation data: six decimal places, polygons above four hectares, valid GeoJSON.
6. Check plots against the 31 December 2020 cut-off with satellite data, and investigate every flagged plot.
7. Build your legality evidence for each country of production across the eight areas of law.
8. Document your risk assessment and mitigation, using the country classification and the Article 10 criteria.
9. Update contracts and supplier onboarding to require EUDR data, segregation and reference numbers.
10. Brief customs brokers and logistics partners on reference numbers and TARIC codes.
11. Set up five-year record retention and an annual review of your due diligence system.
12. Prepare for checks: know who your competent authority is and how you will answer a request for documents.

Frequently asked questions

When does the EUDR apply?

From 30 December 2026 for large and medium-sized operators, all downstream operators and traders, and micro and small operators placing timber already covered by the EUTR. Micro and small operators that were established as such by 31 December 2024 have until 30 June 2027. Products added to Annex I in 2026 are covered from 30 December 2027.

Has the EUDR been postponed again?

No. It has been postponed twice, in December 2024 and December 2025. As of 22 October 2026, no proposal to change the dates has been made, and the Commission has said it does not plan further amendments.

Does the EUDR apply to SMEs?

Yes. Small and medium-sized operators have the same core obligations as large ones. Medium-sized companies follow the 30 December 2026 date. Micro and small operators get until 30 June 2027 if they existed by 31 December 2024, and small primary producers in low-risk countries can use a one-off simplified declaration. SME downstream operators and traders don't need to register in the Information System.

Is leather still covered by the EUDR?

No. Since 18 September 2026, cattle hides, skins and leather are out of scope. Beef, live cattle and edible offal remain covered. Leather is on the agenda for the 2030 review.

Do I need a due diligence statement if I buy from an EU importer?

No. If the products are already covered by the importer's statement, you are a downstream operator or trader. You need to record your suppliers and customers and, if you bought directly from the operator, keep its reference numbers.

What geolocation data does the EUDR require?

Latitude and longitude to at least six decimal places for every plot where the commodity was produced. Plots of up to four hectares can be a single point; larger plots need a polygon. For cattle, every establishment where the animals were kept. Data is uploaded in GeoJSON format.

How does traceability work for cattle?

Operators must give the geolocation of every establishment where the cattle were kept, not only the farm where the calf was born. That includes the farms, feedlots and pastures where the animals were raised, fattened or grazed. Point coordinates are enough for each establishment. The date of production for cattle is the date of birth, so cattle born before 29 June 2023 are out of scope. These rules apply to all operators, whatever their size.

Can producers map their own plots?

Yes. Producers, or cooperatives on their behalf, can record plot coordinates themselves, for example with a smartphone GPS app, and share them with their buyers. The operator that files the due diligence statement remains legally responsible for the data, so it should check the coordinates, for example against satellite imagery, before relying on them.

What if there is no land registry or formal land title?

A plot doesn't need a land registry entry or a formal title to be geolocated. Land actually used for production, including public or communal land, can be mapped as a plot. For the legality requirement, operators need adequately conclusive and verifiable evidence of the right to use the land under the law of the country of production. That can include customary or communal use rights where national law recognises them.

Is certification enough to comply with the EUDR?

No. Certification can provide useful evidence for the risk assessment, but it doesn't replace due diligence or the statement, and the operator remains liable.

Is mass balance allowed under the EUDR?

No. Products must be traceable to the plots where they were produced. Mixing compliant goods with goods of unknown origin makes the mixed product non-compliant.

What happens if part of a shipment is non-compliant?

The non-compliant products must be identified and separated before the shipment is placed on the market or exported. If they can't be separated, the whole shipment is non-compliant. In the Commission's example, a mixed shipment from several hundred plots can become non-compliant because one plot was deforested after 2020.

Is there a minimum quantity below which the EUDR doesn't apply?

No. There is no threshold by quantity or value.

Does the EUDR apply to EU farmers and forest owners?

Yes. An EU farmer or forest owner who places their own relevant commodities on the market is an operator. Because all EU countries are classified as low risk, simplified due diligence applies, and micro and small producers can use the one-off simplified declaration.

Does the EUDR apply to smallholders outside the EU?

Only if they place products on the EU market themselves. Smallholders selling to a cooperative, exporter or trader have no direct obligation, but their buyers will need their plot geolocation and legality evidence.

Does the EUDR apply to exports?

Yes. Exporting relevant products from the EU is covered in the same way as placing them on the market. Downstream operators exporting goods already covered by a statement use a dedicated customs code instead of a reference number.

Is wooden packaging covered?

Packing material used only to support, protect or carry another product is out of scope. Pallets, crates and packing cases placed on the market as products in their own right are covered.

What are the penalties for breaching the EUDR?

They are set nationally but must include maximum fines of at least 4% of EU-wide annual turnover for companies, confiscation of products and revenues, exclusion from public procurement and funding for up to 12 months, and temporary market bans. Intentional breaches can also be a criminal offence under the Environmental Crime Directive.

References

[1] FAO (2025). Global Forest Resources Assessment 2025. fao.org

[2] Regulation (EU) 2023/1115 on deforestation-free products, consolidated text of 26 December 2025. EUR-Lex

[3] Regulation (EU) 2025/2650 of 19 December 2025 amending Regulation (EU) 2023/1115. EUR-Lex

[4] European Commission (2026). Simplification review on Regulation (EU) 2023/1115, COM(2026) 191 final, 4 May 2026. EUR-Lex

[5] Commission Delegated Regulation (EU) 2026/2102 amending Annex I of Regulation (EU) 2023/1115, OJ L of 17 September 2026; and European Commission, EU Deforestation Regulation Update, 17 September 2026. EUR-Lex · Commission

[6] European Commission (2026). Guidance document for Regulation (EU) 2023/1115 on deforestation-free products, C/2026/3896, OJ C of 20 July 2026. EUR-Lex

[7] Commission Implementing Regulation (EU) 2026/1565 of 13 July 2026 amending Implementing Regulation (EU) 2024/3084 as regards the Information System; and European Commission, Commission updates product scope and tools to support EUDR, 13 July 2026. EUR-Lex · Commission

[8] European Commission (2026). Implementation of the EU Deforestation Regulation: Frequently Asked Questions, version 5 (April 2026), revised 21 August 2026. Commission

[9] European Commission (2026). Proposal for a Council Regulation as regards the adaptation of certain requirements in the Union outermost regions, COM(2026) 661 final, 10 September 2026.

[10] Deutscher Bundestag (2026). Government bill for the German EUDR implementing act, printed paper 21/8278, 30 September 2026; first reading 8 October 2026.

[11] Directive 2013/34/EU (Accounting Directive), Article 3, as amended by Commission Delegated Directive (EU) 2023/2775. EUR-Lex

[12] European Commission. EUDR Information System: GeoJSON file description and due diligence statement API reference. Commission

[13] Commission Implementing Regulation (EU) 2025/1093 on the classification of countries; and European Commission, Country classification list. Commission

[14] ESG Today (2025). EU lawmakers reject EUDR's country risk system in new setback to Deforestation Regulation, July 2025. ESG Today

[15] Directive (EU) 2024/1203 on the protection of the environment through criminal law, Articles 3(2)(p), 5 and 7. EUR-Lex

[16] European Commission. EUDR roles and responsibilities. Green Forum