EUDR Explained: What the EU Deforestation Regulation Means for Freight

Regulation (EU) 2023/1115, the EU Deforestation Regulation (EUDR), says that seven commodities and the products made from them cannot be placed on the EU market, or exported from it, unless they are deforestation-free, were produced legally in the country of origin, and are covered by a due diligence statement. As of 25 September 2026, the main obligations apply from 30 December 2026 for most companies, and from 30 June 2027 for natural persons and micro and small enterprises that qualify. Those dates have moved before, so read the next section before you plan anything around them.

The application dates, and why you should treat them as provisional

The dates are set by Article 38 of the regulation, as replaced by Regulation (EU) 2025/2650. Here is the sequence, taken from the Official Journal texts:

Two details in Article 38 matter in practice. First, the later 30 June 2027 date covers operators that are natural persons or micro or small undertakings established as such by 31 December 2024, and it does not extend to products covered by the annex to the old EU Timber Regulation, so a small timber business does not get the extra six months. Second, the old Timber Regulation (EU) No 995/2010 is repealed from 30 December 2026, although it keeps applying until 31 December 2029 to timber produced before 29 June 2023 and placed on the market from that date.

What has happened since, as of September 2026. The 2025 amendment required the Commission to carry out a simplification review by 30 April 2026. The Commission's report, COM(2026) 191 final of 4 May 2026, concluded that it did not consider it appropriate to propose further amendments to the basic legal text, and it presented updated guidance and FAQs, a draft change to the product list, and changes to the information system instead. On 17 September 2026 the Official Journal published Commission Delegated Regulation (EU) 2026/2102, adopted 13 July 2026, which changes the product list in Annex I (covered below). We found no proposal in those documents to move the application dates again.

That is a statement about what was published on the date above, not a forecast. The regulation has been postponed twice, each time close to the deadline, and a third change would need the European Parliament and Council. Check the European Commission's EUDR page before you commit to a plan, and do not treat anything in this guide as legal advice.

The seven commodities and the products made from them

The scope is defined by Annex I, which lists products by Combined Nomenclature (CN) code, so your HS classification decides whether a shipment is in scope. The seven commodities are cattle, cocoa, coffee, oil palm, rubber, soya and wood. The list is broad on the derived side:

• Cattle: live cattle, beef and certain offal and preserved meat.
• Cocoa: beans, shells, paste, butter, powder, and chocolate (heading 1806).
• Coffee: heading 0901, meaning green and roasted coffee, husks and coffee substitutes containing coffee.
• Oil palm: palm oil and kernel products, oilcake, and a set of chemical derivatives such as glycerol and fatty acids (chapters 29 and 38).
• Rubber: natural rubber in primary forms, plus a range of rubber goods including new pneumatic tyres.
• Soya: beans, flour and meal, soya oil, and the oilcake used in animal feed.
• Wood: chapter 44 headings from fuel wood to plywood and furniture parts, plus pulp and paper headings.

Two freight-specific details are worth knowing. The regulation's Annex I entry for wooden packing cases and pallets (heading 4415) carries a carve-out for packing material used exclusively to support, protect or carry another product, so the pallet under your cargo is not what triggers the regulation. And the products list has just changed:

• Delegated Regulation (EU) 2026/2102 removes cattle hides, skins and leather from Annex I. The Commission's announcement also lists retreaded tyres, soybeans for sowing, articles of vulcanised rubber, conveyor and transmission belts, and aircraft and motor vehicle seats as removed.
• It adds frozen cattle tongues, soluble coffee (CN 2101 11 00) and certain palm oil derivatives, and those additions apply from 30 December 2027, not 2026.

Because the list is being edited, pull the current Annex I from EUR-Lex when you classify a product, and do not rely on a supplier's memory of an older version.

The three legal tests

Article 3 sets three conditions, and all three must be met for a product to be placed on the market or exported:

1. Deforestation-free. The commodity was produced on land that was not subject to deforestation after the regulation's cut-off date of 31 December 2020 (and, for wood, harvested without forest degradation after that date).
2. Legal. It was produced in accordance with the relevant legislation of the country of production, which covers matters such as land use rights and environmental rules.
3. Covered by a due diligence statement. A statement has been made available through the EU information system before the goods are placed on the market or exported.

Note the wording of the legality test: it is about the producing country's own law, not EU law. That is why the evidence you collect is about land tenure, permits and local rules as much as about satellite maps.

Who does what: operator, downstream operator, trader

The 2025 amendment reshaped the roles, and it is the most useful thing to understand if you sit in the middle of a supply chain.

Under Article 5 as replaced in 2025, downstream operators and traders must not place products on the market or export them without the supplier and customer information, and those that are not SMEs must also register in the information system. The first downstream operator or trader must also hold the reference number of the statement (or the declaration identifier). They are not required to ascertain that due diligence was exercised or to submit statements, though non-SME ones who learn a product is non-compliant must inform the authorities and, where concerns are substantiated, verify that due diligence was done before moving the goods.

What due diligence actually consists of

Articles 8 to 11 describe due diligence as three steps: collect information, assess the risk that the product is non-compliant, and mitigate any risk found. Under Article 9, the operator collects and keeps for five years, with evidence:

• the product description and, for wood, the common and full scientific species name;
• the quantity, in kilograms of net mass and, where applicable, the supplementary unit against the HS code;
• the country of production and, where relevant, parts of it;
• the geolocation of all plots of land where the commodity was produced, plus the date or time range of production (for cattle, the establishments where they were kept);
• the name, address and email of suppliers and of customers;
• conclusive, verifiable information that the goods are deforestation-free and were produced legally.

Geolocation, in plain terms

Under the definitions in Article 2, geolocation means latitude and longitude coordinates using at least six decimal digits. For plots of more than four hectares (other than for cattle), the operator must supply polygons with enough points to describe the perimeter. Micro or small primary operators may instead give the postal address of the plots or establishment, if it clearly corresponds to the location (Article 4a). Where a product mixes output from many plots, all of them must be included, which is why mixed or bulked loads are the hard case.

Country benchmarking and simplified due diligence

Article 29 creates three risk tiers for countries, or parts of them. Implementing Regulation (EU) 2025/1093 of 22 May 2025 lists the countries classified as low or high risk. Four are high risk: Belarus, the Democratic People's Republic of Korea, Myanmar and the Russian Federation. A long list is low risk, and every country not listed stays at standard risk. Check the annex for your origin because the tier changes the workload: under Article 13, an operator whose commodities all come from low-risk countries can skip the risk assessment and mitigation steps (Articles 10 and 11), but must still hold documentation showing that the risk of mixing with products of unknown or higher-risk origin is negligible. The tier does not remove the duty to collect information and file the statement.

The due diligence statement and the information system

Operators submit the statement electronically through the EU information system that the Commission built under Article 33, which entered service on 4 December 2024. It is accessed through the Commission's TRACES platform. The content is set out in Annex II: the operator's name, address and EORI number, the HS code and description, quantity, country of production and geolocation, and a declaration that due diligence was carried out and that no or only a negligible risk was found. The system returns a reference number, which the operator passes to its customers and which is quoted on the customs declaration. A separate verification number exists as a security check, so treat the two numbers differently: the reference number travels with the goods, while the verification number should be shared only with whoever has to link to the statement.

The operator can mandate an authorised representative established in the EU to submit the statement on its behalf, but Article 6 requires a written mandate and keeps the responsibility with the operator.

What a freight forwarder or customs agent carries, and what it does not

This is where the confusion is greatest, so here is what the text says.

• The duty to do due diligence sits with the operator. An operator is the person who first places the products on the EU market or exports them. A forwarder that simply moves the goods and does not buy, sell or place them on the market is not an operator on that basis. The regulation does not turn a carrier into the party that certifies the supply chain.
• A forwarder can become responsible in three ways. If it is itself the importer of record and places the goods on the market, it is an operator. If it accepts a written mandate as authorised representative, it submits the statement, although the operator keeps the legal responsibility. And if it lodges the customs declaration, it must make the reference number available to customs (below).
• Customs declarants carry a specific duty. Under Article 26(4), as amended, the person lodging the customs declaration for release for free circulation or export must make the due diligence statement reference number (or the declaration identifier for micro or small primary operators) available to customs before release, unless the number is passed through the EU customs interface. It does not apply to the export of a product by a downstream operator.
• Traders keep records. A forwarder that owns the goods in transit or resells them may count as a trader, with the record-keeping duties in the table above.

Which of these applies to a given forwarder depends on its contract, on who is importer of record, and on national rules, so get your own legal advice. What we can say from the text is that the safe practice is to write it down: who is the operator, who lodges the declaration, and who supplies the reference number. Our guide on whether you need a customs broker covers the broader question of who files what.

What happens at the border

Under Article 26, relevant products placed under release for free circulation or export are subject to controls. Customs authorities carry out risk-based checks on the customs declarations, and the reference number must be available before release. Competent authorities (the national EUDR enforcement bodies) decide which consignments to check for compliance. Where the status of a statement shows that a product has been flagged for checking, customs must suspend release (Article 26(7) as amended). Until the electronic interface between national customs systems and the information system is in place, customs and competent authorities exchange information under Article 27 instead of automated status checks. Article 28 now sets 1 December 2029 as the date by which that interface must be in place.

In practice, expect a missing or wrong reference number, a mismatch between the HS code on the declaration and on the statement, or a quantity outside the tolerance the statement allows, to cause delay. A consignment stopped for checks accrues demurrage and storage in the meantime, so the paperwork is a cost issue as much as a legal one. For the wider process see customs clearance explained.

What penalties the regulation requires

Article 25 leaves the detail of penalties to each Member State, but sets a floor: penalties must be effective, proportionate and dissuasive and must include fines, confiscation of the products and of revenues, temporary exclusion from public procurement for up to 12 months, and temporary bans on placing products on the market. For a legal person the maximum fine must be at least 4 percent of its total annual Union-wide turnover in the previous financial year. National levels will differ, and we have not tried to summarise them.

What a shipper should have ready

If you import or export in scope goods, assemble this before booking, not at the port:

1. The correct HS or CN code for each product, checked against the current Annex I.
2. Your role in writing: operator, downstream operator or trader, and who is importer of record.
3. Supplier details: name, postal address, email for every party you buy from, and every customer you supply.
4. Country of production and its risk tier under Regulation (EU) 2025/1093.
5. Plot geolocation with production dates, or the postal-address alternative if you qualify as a micro or small primary operator.
6. Legality evidence: land rights, permits and the local laws relevant to the commodity. The Commission's FAQ indicates the detail expected should be proportionate to risk.
7. The reference number and verification number from the information system, or the declaration identifier for small primary producers, plus the EORI number.
8. Retention: keep records for at least five years, in a form you can produce to a competent authority. Our customs audit readiness guide covers how to organise them.

If your goods also fall under the EU carbon border mechanism, the two regimes run separately, so see the CBAM importer checklist for that side.

Myths worth correcting

• "Forwarders must file the statement for every shipment." The obligation sits with the operator. A forwarder files only as a mandated representative or if it is the operator.
• "The law starts in 2025." That was the date after the first postponement. As of September 2026 the date is 30 December 2026, with the small-operator date of 30 June 2027.
• "Anything from a low-risk country is exempt." Low risk reduces the risk assessment and mitigation steps. It does not remove the duty to collect information, geolocate and file.
• "Leather is in scope." It was in the original list, and the July 2026 delegated act removes it. Frozen cattle tongues, soluble coffee and certain palm derivatives are added from December 2027.

Finding help on the lane

If you ship in scope goods into or out of the EU and need a forwarder or customs agent who can handle a lane or commodity, you can browse the CargoLinked directory by country, city or trade lane. Listings are self-published, so check each company's credentials and ask directly how it handles EUDR paperwork. Or post the shipment on the requests board, where eligible forwarders can quote against the details you supply; each quote carries a validity date and expires after it.