EUDR Regulation: Obligations, Deadlines, and Implementation for Businesses

The EUDR requires companies to ensure that certain products entering the European market have not contributed to deforestation. This applies to large and medium-sized companies starting at the end of 2026, and to micro and small companies starting in mid-2027. In this article, you’ll learn about the applicable deadlines, who is affected, and how to implement the requirements step by step.

Why the EUDR Works Differently from Other Due Diligence Laws

Over the past 30 years, the world has lost an area of forest larger than the land area of the European Union. At the same time, the EU is one of the largest importers of products such as soy, green coffee, and raw cocoa, which are linked to deforestation. As a first step, the EU had already adopted the EU Timber Regulation (EUTR) in 2013, which was implemented in Germany through the Timber Trade Security Act. The EUDR strengthens this approach as part of the Green Deal and imposes strict requirements for traceability and due diligence throughout the entire supply chain. It makes no difference whether the forest in question is located inside or outside the EU.

The key difference from other due diligence laws, such as the LkSG: The LkSG focuses on the company and its obligations to take action. The EUDR, on the other hand, focuses on the product and examines actions that have already been taken, rather than objectives.

Regulatory Roadmap: From Adoption to Effective Date

The EUDR has undergone several changes since its adoption. Here is an overview of the key milestones:

May 31, 2023: The European Parliament and the Council of the EU adopt Regulation (EU) 2023/1115.
June 29, 2023: The EUDR takes effect, and a transition period begins. Originally scheduled effective date: late 2024.
November 2024: Following criticism from the business community and member states, the European Parliament decides on an initial one-year postponement.
November 26, 2025: The European Parliament finally approves a second postponement for another year, as well as structural relief measures, as set forth in Regulation (EU) 2025/2650, published on December 23, 2025. This version is therefore applicable law, not merely an announcement.
May 4, 2026: The European Commission publishes its previously announced implementation report, along with a simplification package. This includes the fourth edition of the official FAQs (as of April 2026) as well as the draft delegated act amending Annex I. At the time of publication, this package was a proposal, not a regulation already in effect.
July 13, 2026: The European Commission adopts the delegated act amending Annex I (scope of products) as well as an accompanying implementing act regarding the EUDR information system. Both legal acts will then undergo the standard two-month review period by the European Parliament and the Council, which is set to run until around mid-September 2026. Until this period has elapsed, the amendments will not yet be definitively in force.
July 20, 2026: The European Commission publishes the third edition of its EUDR guidelines in the Official Journal of the EU (Notice C/2026/3896), including, among other things, more precise definitions of market operators, micro and small primary producers, downstream market operators, and traders.

Current Status (August 2026): The effective dates (see below) are legally binding under Regulation (EU) 2025/2650. The simplifications to Annex I proposed in May were adopted as a delegated act on July 13, 2026, but have not yet entered into force, as the review period by the Parliament and the Council is still ongoing. It’s worth checking out our EUDR FAQ to stay up to date on the latest developments.

When does the EUDR Regulation take effect?

After two postponements, the following schedule—which is legally binding under Regulation (EU) 2025/2650—is currently in effect:

Effective December 30, 2026, for large and medium-sized companies
Effective June 30, 2027, for micro and small businesses

For products, a retroactive effective date also applies: Goods for which forests were cleared or damaged on or after December 31, 2020, are subject to the ban on first importation, placing on the market, and export.

For products newly added to Annex I by the delegated act of July 13, 2026 (see the section “Which products are covered by the EUDR?”), an additional transition period until December 30, 2027, is provided for, provided that the delegated act survives the parliamentary scrutiny period without amendment.

Who is affected by the EUDR?

The regulation now distinguishes between four roles, after Regulation (EU) 2025/2650 expanded the original two-category system to include two additional categories:

Market participants. The affected products are imported into the EU market for the first time, produced there, or exported from there.
Micro- or small-scale primary producers. A new, separate subcategory of market participants: natural persons or microenterprises that produce relevant commodities themselves and are subject to simplified reporting requirements under Article 4a.
Downstream market participant. Any person who places on the market or exports a relevant product that was manufactured using other relevant products for which a due diligence statement or simplified declaration has already been provided. Example: A chocolate manufacturer who processes cocoa beans that have already been declared deforestation-free into chocolate bars.
Retailer. The affected products are made available on the EU market without the company being a market participant or a downstream market participant.

The classification of a company as a large, medium, small, or micro-enterprise is based on the definition set forth in the Accounting Directive 2013/34/EU. A company is considered large or medium if it exceeds at least two of the following thresholds:

50 employees
€10 million in revenue
Total assets of €5 million

Micro and small businesses will benefit from the extended deadline through June 30, 2027, as well as from a reduced list of requirements.

Which products are covered by the EUDR?

The regulation covers raw materials and products made from wood, palm oil, coffee, cocoa, beef, soy, and rubber, broken down by Harmonized System (HS) codes. There are no threshold or volume limits for the affected products; the listed HS code is the sole determining factor.

Exceptions include, among others: fully recycled goods, instruction manuals, bamboo products, and packaging materials whose sole purpose is to protect or transport other goods. Processed products that are only remotely related to the original raw material, such as gelatin, are also exempt. If a product contains multiple relevant raw materials—such as a chocolate bar containing cocoa powder, cocoa butter, and palm oil—the due diligence requirement applies only to the primary raw material listed on the left in Annex I; in this example, that would be cocoa.

Annex I is undergoing changes: With the delegated act of July 13, 2026, the European Commission has decided to amend the scope of products, a change that remains subject to review by the European Parliament and the Council until around mid-September 2026. The proposed changes include, among other things:

Newly added: instant coffee, frozen beef tongues, and certain palm oil derivatives such as fatty alcohols, glycerin, and soap products. While leather bags remain excluded, pure palm oil soap could be covered in the future if the legislation ultimately takes effect.
Deleted: Cowhides, hides, and leather; retreaded tires (only the new tread pattern); soybeans for seed; and certain rubber products.
A transition period through December 30, 2027, is provided for newly added products; products that have been removed are eliminated immediately upon the effective date.

Since the legal act has not yet formally entered into force, this paragraph should be reviewed once more to ensure it reflects the current status before final approval.

What requirements must products meet under the EUDR?

As of the respective effective date, the raw materials and products listed may only be placed on the market, made available, or exported if three conditions are met:

Deforestation-free. The products were produced without converting forest land into agricultural land or plantations after December 31, 2020, regardless of whether the deforestation was legal in the country of origin.

Compliance with the law in the country of origin. Environmental and human rights regulations were complied with, including species protection, anti-corruption measures, labor rights, the UN Declaration on the Rights of Indigenous Peoples, and applicable trade law.

Statement of Due Diligence. A risk assessment is available for the product, due diligence requirements have been met, and there is no risk of deforestation or only a negligible risk. Micro and small-scale primary producers may submit a one-time simplified declaration in lieu of a full due diligence statement.

What obligations apply to market participants, downstream market participants, and traders?

Market participants conduct a risk assessment, mitigate identified risks, and submit a due diligence statement via the EU information system TRACES. This requires geographic data for all parcels of land on which the products were produced. A before-and-after comparison shows whether deforestation has occurred on the respective plot of land. In addition, evidence of compliance with the legal requirements of the country of origin must be collected, which requires close cooperation with the upstream supply chain. Under certain conditions, micro- or small-scale primary producers may provide their mailing address instead of the geolocation of their land parcels and are generally not required to conduct their own risk assessment.

Downstream market participants process or combine products that have already been declared to create new, similarly listed products. According to the European Commission’s current interpretation, their obligation to record the reference numbers of upstream due diligence statements is passive: Upstream market participants must provide the reference numbers; downstream actors are not required to proactively request them on their own or to verify the content of each individual declaration. Long-term retention can be handled through existing standard business documentation, such as invoices. However, the legal responsibility for ensuring a product is deforestation-free remains with them.

Retailers may rely on the reference numbers of existing due diligence statements when reselling the products. If a statement is missing, they are responsible for submitting it. Large retailers must also conduct random spot checks of the available risk assessments. SME retailers are exempt from the requirement to submit their own due diligence statement.

Micro and small enterprises benefit from a more limited set of obligations: fewer information requirements regarding the downstream supply chain and no public reporting requirement. Large and medium-sized enterprises, on the other hand, must report publicly each year on their risk assessments, due diligence processes, and measures taken (Article 12(3) of the EUDR); the first report for the year 2027 is due after December 30, 2027. According to the European Commission’s official FAQs, companies that already publish comparable information under the CSRD or the CSDDD are not required to report this information twice.

Severe penalties continue to apply for violations: Member States must establish a fine range of at least 4 percent of a company’s annual revenue, in addition to the seizure of affected goods and temporary exclusion from public tenders. The simplification package of May 2026 did not change this lower limit.

Five Steps to EUDR Implementation

Understanding the status quo. Determine the size category of your company, identify the affected products, and clarify your role as a market participant, downstream market participant, or distributor.
Collect data. Record product descriptions, quantities, suppliers, and countries of origin. The EUDR also requires the geolocation of all properties where the raw materials were produced, retroactively back to December 31, 2020.
Assess risks. Assess the risk of deforestation based on the country of origin, the deforestation rate there, the political and social situation, and the complexity of the supply chain. The European Commission provides a benchmarking system for this purpose that classifies producer countries into risk categories.
Mitigate risks. Work with suppliers to develop codes of conduct and monitoring mechanisms, and verify compliance through audits or additional documentation.
Document and report. Submit a due diligence statement for each affected batch of goods. Large and medium-sized companies also report publicly on their due diligence processes on an annual basis, ideally as part of their CSRD report.

Do you have questions about the EUDR or need assistance with implementation? Contact us for a no-obligation consultation.