EUDR deforestation regulation: products, dates and obligations

Current dates

Regulation (EU) 2025/2650, published in the Official Journal on 23 December 2025, postponed and simplified the application of the EUDR.

The Commission had to carry out a simplification review by 30 April 2026. In its May 2026 report it did not propose reopening the text of the regulation, only targeted measures: updated guidance, a change to the product list and simplifications in the information system.

Which products are covered

Seven commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood, plus the derived products listed in Annex I, such as chocolate, furniture, tyres and paper. Whether a product is covered depends on its commodity code in Annex I, so classification is the starting point; the rules are covered in HS and CN codes and tariff classification.

The scope is changing:

• the 2025 amendment removed printed products,
• on 13 July 2026 the Commission adopted a delegated act amending Annex I. According to the Commission, it removes, among others, cattle hides, skins and leather, retreaded tyres, soybeans for sowing, certain vulcanised rubber articles, conveyor and transmission belts, and aircraft and motor vehicle seats, and adds soluble coffee, certain palm oil derivatives and frozen cattle tongues, with the new products covered from 30 December 2027. A delegated act only enters into force after the scrutiny period of Parliament and Council, so check whether it already applies.

For exporters from the Philippines, note that coconut is not one of the seven EUDR commodities. Coconut oil as such is therefore not covered, but blends containing palm oil derivatives may be; check at the level of the commodity code. Palm oil, rubber, cocoa, coffee and wood from the Philippines are covered. Coconut oil imports are covered in a separate guide.

Three conditions for market access

A product covered by the EUDR may be placed on the EU market or exported only if:

1. it is deforestation-free, meaning it comes from land not deforested after 31 December 2020 (and for wood, harvesting did not cause forest degradation),
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 a simplified declaration where that applies).

Due diligence step by step

The operator that first places the product on the market carries out due diligence in three stages:

• Information collection: description and quantity of the product, country of production, supplier and customer, geolocation of all plots of land where the commodity was produced, and evidence of deforestation-free status and legality.
• Risk assessment: whether there is a risk of non-compliance, taking into account the country risk category, supply chain complexity and the risk of mixing with products of unknown origin.
• Risk mitigation: additional documents, audits, on-site checks before the product goes to market.

The due diligence statement is submitted in the EUDR information system and receives a reference number, which is quoted in the customs declaration among other places.

Who does what after the 2025 changes

• The operator first placing the product on the market submits the due diligence statement. Only that operator.
• Micro and small primary operators in low-risk countries that grow or obtain the commodity themselves submit a simplified declaration instead of full due diligence.
• Downstream operators and traders (processors, distributors, exporters of products made from already checked commodities) do not submit their own statements. They must collect and keep for five years information on suppliers and customers and the reference numbers; the larger ones register in the information system.

Country benchmarking

Implementing Regulation (EU) 2025/1093 classifies countries as low, standard or high risk. For commodities from a low-risk country simplified due diligence applies (without the risk assessment and mitigation stages, unless there are signs of non-compliance), and the risk category also drives how often authorities check operators. Check the current category of your commodity's country of origin in the Commission's list.

Penalties

Member states set penalties, but the regulation requires the maximum fine for legal persons to be at least 4% of total annual EU turnover. Confiscation of products and revenues and temporary exclusion from public procurement are also provided for.

How to prepare

1. Review your range and commodity codes; identify what is covered now and what from 2027.
2. Establish your role: operator placing on the market, downstream operator or trader.
3. Register in the EUDR information system.
4. Ask suppliers for geolocation data and legality documents in new contracts now; for smallholder supply chains, data collection takes time.
5. Add to contracts an obligation to provide data, a right to audit and consequences of non-compliance.
6. Plan checks on suppliers, not only on documents; see how to verify a foreign supplier.

Like CBAM, the EUDR puts the obligation to hold producer data on the importer. Hiram does not verify EUDR documents, but when negotiating on the platform you can record requirements for geolocation data and documents in versioned offer terms. If you are looking for a supplier of coffee, cocoa, wood or rubber, browse the market.

A simple habit that pays off is a per-supplier geolocation ledger: one sheet pairing each plot polygon with its harvest season and the due diligence statement reference it supports.

Checking each lot before shipment is the core control; a quarterly plot-to-lot reconciliation on top of it catches mismatched batch records long before a consignment reaches the border.

Sources

• European Commission: Regulation on deforestation-free products (opens in a new tab)
• European Commission: Commission updates product scope and tools to support EUDR (13.07.2026) (opens in a new tab)
• Access2Markets: Delay until December 2026 and other developments in the implementation of the EUDR regulation (opens in a new tab)
• European Commission: Report from the Commission to the Council and Parliament on the EUDR, COM(2026) 191 (PDF) (opens in a new tab)
• European Commission: Deforestation Regulation implementation (opens in a new tab)
• Regulation (EU) 2023/1115, EUR-Lex (opens in a new tab)
• Stibbe: The amended EUDR, what has changed and what has remained? (opens in a new tab)