Regulation (EU) 2023/1115 — the EU Deforestation Regulation — applies from , and the obligation it creates is a due diligence statement filed before a relevant product goes on the Union market. The date is the one most companies have wrong, because it moved twice; the Commission's simplification review of May 2026 left it unchanged. The amendment that set it, Regulation (EU) 2025/2650 of 19 December 2025, also rewrote who has to file at all. This guide covers who is in which tier, what the statement actually needs behind it, and why the real deadline for an exporter is earlier than the legal one.
What the EUDR asks for
The EUDR is a due diligence regulation, not a labelling one. It asks a company to establish that a commodity was not produced on land deforested after 31 December 2020, and to be able to show the work. Three steps run underneath it: collect information about the product and its origin, assess the risk that it does not comply, and mitigate that risk until it is negligible.
The information step is where the regulation is unusual, and where it is expensive. It is not enough to know the country. The regulation asks for the geolocation of the plots of land where the commodity was produced — coordinates, not a supplier address. Everything else on the form is administrative. The coordinates are the project.
The seven commodities — and the products that carry them
| Commodity | Where it reaches you | What to watch |
|---|---|---|
| Cattle | Live cattle, beef | Leather and hides left the list on 18 September 2026; frozen cattle tongues join on 30 December 2027 |
| Cocoa | Chocolate, confectionery | The finished-goods importer, not the bean trader, is often the operator |
| Coffee | Green and roasted coffee | Blends multiply the number of plots behind one product; soluble coffee joins on 30 December 2027 |
| Oil palm | Palm oil, palm kernel oil and listed derivatives such as glycerol and fatty acids | Derivatives sit deep in a chemicals specification; certain soaps join on 30 December 2027 |
| Rubber | Natural rubber, new tyres, inner tubes, gloves | Conveyor belts and other vulcanised rubber articles left the list on 18 September 2026 |
| Soya | Beans, flour, oil, oilcake for feed | Feed makes livestock products indirectly exposed |
| Wood | Furniture, paper, wooden packaging sold as a product | Printed books and newspapers left the list in December 2025 |
The list of commodities is closed, and the derived products are set out in the regulation's annex. The trap is not the commodity — it is the derived product. A furniture exporter is a wood operator. And the annex itself moves, so check it against Delegated Regulation (EU) 2026/2102 before assuming a product is in or out.
Who files: the three tiers the 2025 amendment created
This is the part that changed, and most summaries written before December 2025 are now wrong.
| Tier | Who | What they file |
|---|---|---|
| Operator | First places a relevant product on the Union market, or exports it | A full due diligence statement |
| Downstream operator / trader | Further along the chain | Nothing. Article 5(1) requires only that they hold the required information |
| Micro or small primary operator in a low-risk country | Small producers at the top of the chain | A one-time simplified declaration under Article 4a(2), with the content set out in Annex III |
Read the middle row carefully before treating it as relief. The filing duty is gone; the information duty is not. A trader who cannot produce the required information cannot lawfully place or make available the product. In practice that means the same questions still travel down the chain — they simply arrive as a customer's demand rather than as your own filing deadline.
The bottom row is the one that surprises people in a good way. Annex III's simplified declaration asks for operator details, a product description, the country of production and the geolocation or postal address of the production sites. For a small primary operator in a low-risk country, that is a materially lighter route than the full statement, and it is filed once rather than per consignment.
The dates
| Date | What | Status |
|---|---|---|
| 23 December 2025 | Regulation (EU) 2025/2650 published in the Official Journal | In force |
| EUDR applies — Article 38(2) | Binding | |
| Deferred date for natural persons and micro/small undertakings established as such by 31 December 2024 — Article 38(3) | Binding |
Two details in the second row do work that companies miss. It applies to the operator's size, and it applies only to undertakings that already existed in that form on 31 December 2024 — a company incorporated in 2025 to handle EU imports does not get the later date by being small. Check the incorporation date alongside the headcount.
Walkthrough: a furniture exporter shipping into the EU
A representative scenario. A manufacturer outside the EU ships oak dining furniture to two EU importers. It does not consider itself a commodity business; it buys sawn timber from three domestic suppliers and assembles.
Month one — who is the operator. The first question is not about wood, it is about roles. The EU importers place the product on the Union market, so they are the operators and they file. The manufacturer files nothing under the EUDR. This is the moment the project is nearly abandoned as "not our obligation" — and the moment it should not be, because the operators cannot file without data that only the manufacturer can get.
Month two — the geolocation wall. The importers ask for the coordinates of the harvest plots. Supplier one has them, from a certification scheme it already belongs to. Supplier two has the forest management unit but not plot-level coordinates. Supplier three buys from intermediaries and cannot say. One of three chains is ready; the other two need work that runs through parties the manufacturer does not contract with directly.
Months three to five — the commercial fix. The gap is contractual, not technical. Purchase agreements are reopened to require origin data as a delivery condition, and supplier three is dual-sourced against a supplier that can produce coordinates. That is a sourcing decision with a price attached, taken for a regulatory reason — which is why it needs a decision-maker, not a compliance officer.
The counterfactual. Suppose the manufacturer had read that traders no longer file and concluded the December 2025 amendment had removed the problem. Nothing about its own position would have changed — it never filed anyway — but its customers would still have been unable to file. The first consequence would not have been a fine; it would have been an importer switching to a supplier who could answer, some time in the autumn of 2026, with no notice and no appeal.
Edge cases
Wooden packaging. Pallets, crates and cases are on the list when they are placed on the market as products in their own right. Used only to support, protect or carry another product, they are outside it: the pallet under a non-listed product does not bring that product into scope, but the company that first places pallets on the market as goods is an operator.
Recycled and reclaimed material. Post-consumer material sits differently to virgin material in the chain. Establish which of your inputs is genuinely reclaimed before assuming the answer, because the classification drives the data you need.
Composite products. A single article can carry two listed commodities. Each one needs its own chain established; there is no "dominant material" shortcut.
Group structure. Which legal entity is the importer of record determines who the operator is. Groups that route imports through one entity concentrate the obligation there — deliberately or by accident.
Being a supplier to an operator. You may have no filing duty and still carry the entire practical burden, because the operator's statement depends on your data. This is the most common position and the least well described in the guidance.
Zoom out: the same shape as the battery rule
The EUDR is not a one-off. Put it beside the battery due diligence obligation and the resemblance is exact: a company-level duty, a closed list of materials, risk assessment in defined categories, and evidence that has to come from further upstream than the obliged company can currently see. Our guide to battery due diligence covers the sibling rule, which lands on — eight months after this one.
For an exporter the practical read is the same in both cases, and it is not about the text of either regulation. You will not be the operator, you will not file, and you will still be asked — in writing, by a customer whose own filing depends on your answer. The companies that found the EUDR manageable were the ones already collecting origin data for something else. Our guide for manufacturers outside the EU covers how that pressure travels, and the customs guide covers what happens when the evidence and the border meet.
Frequently asked questions
When does the EU Deforestation Regulation apply?
Who has to submit an EUDR due diligence statement?
Is there a simplified route for small companies under the EUDR?
What is the hardest part of EUDR compliance?
Is the EUDR the same as the digital product passport?
Which products fall under the EUDR?
Sources
- Regulation (EU) 2023/1115 (deforestation-free products) — EUR-Lex — 2026-08-18
- Regulation (EU) 2025/2650 — amending the EUDR as regards certain obligations of operators and traders — 2026-08-18
- Commission Delegated Regulation (EU) 2026/2102 — amending the EUDR as regards the list of relevant commodities and products — EUR-Lex — 2026-10-07
- European Commission (DG Environment) — EU Deforestation Regulation update, 17 September 2026 — 2026-10-07
- — Corrected: the product list now reflects Regulation (EU) 2025/2650 and Delegated Regulation (EU) 2026/2102 (printed products, leather and hides, conveyor belts and other vulcanised rubber articles removed; soluble coffee, certain palm-oil derivatives and frozen cattle tongues to be added); wooden packaging used only to carry another product is outside the scope.
