EUDR FAQ: The Most Important Questions About the Deforestation Regulation

The EUDR FAQ provides companies with answers to the most important questions regarding the EU Regulation on Deforestation-Free Products (EUDR). Who is affected? Which products are covered? How does the due diligence declaration work? And what exactly does “deforestation-free” mean?

Answers to these and many other questions can be found in the official FAQs from the European Commission and the Federal Office for Agriculture and Food (BLE). Given the complexity and scope of these documents, we have compiled a selection of particularly practical questions here and presented them in an easy-to-understand format—without claiming to be exhaustive, but with a clear focus on the essentials.

EUDR FAQ: Basics

What is the EUDR?

To counteract the ongoing global deforestation, the European Union has established a binding legal framework. The EUDR (EU Regulation on Deforestation-Free Products) is a European Union regulation that took effect in June 2023. It requires companies to ensure that certain raw materials and products—such as wood, soy, palm oil, coffee, and cocoa—are not linked to deforestation or forest degradation. The goal is to allow only products that are verifiably deforestation-free on the EU market.

When does the EUDR take effect?

The EUDR was adopted by the European Parliament and the Council of the EU on May 31, 2023, and entered into force on June 29, 2023. The date of application, originally scheduled for the end of 2024, was postponed twice, most recently by Regulation (EU) 2025/2650, which the European Parliament finally adopted on November 26, 2025, and which was published in the Official Journal on December 23, 2025.

Current Status (August 2026): The regulation has been adopted, is legally binding, and is in effect

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

No further postponement of these deadlines has been announced at this time. However, on July 13, 2026, the European Commission adopted a delegated act to amend the scope of products (Annex I), which is still subject to review by the Parliament and the Council until around mid-September 2026; see the question “Which products are affected by the EUDR?” below.

You can find the complete regulatory roadmap, including all intermediate steps, in our article on the EUDR Regulation.

What does the EUDR require?

Relevant raw materials may be placed on the market, made available, or exported only if they:

are deforestation-free, meaning that no forest has been cleared for them since December 31, 2020,
were produced in compliance with the law in the country of origin,
and an electronic statement of due diligence (or, for micro- and small-scale primary producers, a simplified statement) has been submitted.

A product is considered deforestation-free if it does not come from areas that were deforested after December 31, 2020. For wood products, the wood must also not come from forests that were damaged by unsustainable use after that date.

Violations are subject to severe penalties: Member States must establish a fine range of at least 4% of annual turnover, in addition to the seizure of the affected goods and exclusion from public tenders. In particularly serious cases, a ban on trade within the EU is also possible. According to the European Commission’s official FAQ (Version 5, April 2026), the simplification package of May 2026 did not change this fine range.

How does the EUDR apply to composite products?

If a product contains multiple relevant raw materials or ingredients—such as a chocolate bar containing cocoa powder, cocoa butter, and palm oil—the market participant is required to fulfill its due diligence obligations only with respect to the primary raw material and the products derived from it. The raw material listed on the left in Annex I is decisive. In the case of a chocolate bar, this is cocoa; accordingly, the due diligence requirement applies only to cocoa powder and cocoa butter.

Is there a public reporting requirement under the EUDR?

Major market participants are required to report publicly once a year on the implementation of their due diligence obligations (Article 12(3) of the EUDR): specifically, what measures they have taken to fulfill their obligations. Since 2027 is the first full year of application, the first report covering the year 2027 is due after December 30, 2027.

This reporting can be integrated into existing reporting formats. The European Commission has since clarified (FAQ Version 5, April 2026): Companies that already disclose the relevant information under the CSRD or the Corporate Sustainability Due Diligence Directive (CSDDD) are not required to report this information twice. This is provided that the reporting under those directives covers the content required by Article 12(3) of the EUDR.

EUDR FAQ: Impact

Which products are affected by the EUDR?

Products not listed in Annex I of the Regulation are not subject to the requirements of the EUDR, even if they contain relevant raw materials. Similarly, complex products such as cars with leather seats or tires made of natural rubber are not affected, as long as their HS codes are not listed in Annex I. The listed HS code is always the determining factor.

The European Commission may amend the list of affected products by means of a delegated act, and that is precisely what is currently underway: On July 13, 2026, the Commission adopted a delegated act amending Annex I, which is still subject to the parliamentary scrutiny period until around mid-September 2026. Among other things, the act provides for:

New additions to the scope of application: instant coffee, frozen beef tongues, and certain palm oil derivatives such as fatty alcohols, glycerin, and soap products. An example from the previous version of this FAQ stated that soap containing palm oil generally does not fall under the regulation because it is not one of the listed products. That could change for certain palm oil soaps once this regulation finally enters into force, with a transition period lasting until December 30, 2027.
Excluded from the scope of application: cattle hides, skins, and leather; retreaded tires (only the new tread pattern); soybeans for seed; and certain rubber products.

Affected companies should therefore continue to monitor changes to Annex I; this section should be reviewed again once the review period has ended.

A common and often unclear practical example involves packaging: It is subject to the EUDR only if it is marketed as a standalone product. If it is used exclusively for the protection or transport of other goods, the regulation does not apply.

What types of companies does the EUDR distinguish?

Since the adoption of Regulation (EU) 2025/2650, the EUDR no longer distinguishes between just two roles along the supply chain, but rather four:

Market participants are defined as any natural or legal person who, in the course of a commercial activity, first makes relevant raw materials or products available on the EU market or exports them from the EU. These include, above all, primary producers, importers, and exporters. If a company is based outside the EU, the first customer located in the EU is considered the market participant.

Micro or small primary operators (MSPOs) are a distinct subcategory of market participants: individuals or micro-enterprises that produce relevant raw materials themselves. Under Article 4a, they are subject to simplified obligations, such as submitting a one-time simplified declaration instead of a full due diligence declaration and, under certain conditions, providing their mailing address instead of geolocation data.

Downstream market participants convert a product that has already been listed and declared into another product that is also listed. Example: A chocolate manufacturer that processes cocoa beans (HS Code 1801) that have already been declared deforestation-free into chocolate bars (HS Code 1806) and places them on the market or exports them is considered a downstream market participant.

“Distributors” are defined as entities that make relevant products commercially available on the EU market without themselves being market participants or downstream market participants, such as retailers or wholesalers.

Example: Company A, based in the EU, imports deforestation-free rubber and sells it to tire manufacturer B. B uses it to manufacture tires (also listed in Annex I) and resells them to tire dealer C. A is considered a market operator; B is considered a downstream market operator, since it further processes a product that has already been declared. C is considered a distributor, provided that it merely makes the tires available on the EU market.

What size categories does the EUDR establish for companies?

The EUDR distinguishes between SMEs and non-SMEs in many areas, including applicable obligations and the effective date of implementation. The classification in accordance with Directive 2013/34/EU as of the balance sheet date of December 31, 2020, is decisive if at least two of the three thresholds are met:

Micro-enterprises: Total assets up to €450,000, net sales up to €900,000, and an average of up to 10 employees.
Small business: Total assets up to €7,500,000, net sales up to €15,000,000, and an average of up to 50 employees.
Medium-sized company: Total assets up to €25,000,000, net sales up to €50,000,000, and an average of up to 250 employees.
For micro and small businesses, the extended deadline is June 30, 2027.

EUDR FAQ: Implementation

How does the submission of the due diligence statement work?

Before importing, exporting, or placing an EUDR-relevant product on the market, a due diligence statement must be submitted. It confirms that the company has fulfilled its due diligence obligations and that no deforestation risk—or only a negligible one—has been identified. By submitting this statement, the company assumes responsibility for ensuring that the products are deforestation-free. Annex II of the EUDR lists the required information. Micro and small-scale primary producers, on the other hand, generally submit a one-time simplified declaration that need only be updated in the event of significant changes.

The declaration is submitted digitally via the EU information system TRACES (Trade Control and Expert System), not on paper or using a standardized form. Registration and use are already available through the website of the Federal Office for Agriculture and Food (BLE), including a test environment. Upon submission of the due diligence declaration, the company receives a reference number, which is mandatory for the import or export of relevant products and may need to be passed on along the supply chain. The competent authority—in Germany, the BLE—reviews the submitted declarations.

The declaration of due diligence may refer to planned quantities and cover multiple partial shipments within a year. Companies must retain the declarations submitted via TRACES for five years.

How do the duties of care differ?

Market participants that are not SMEs are subject to full due diligence requirements: They must submit a due diligence statement and demonstrate that their products are deforestation-free.

Downstream market participants rely on the reference numbers of due diligence obligations already fulfilled by upstream actors. According to the European Commission’s interpretation in FAQ Version 5 (April 2026) and the guidelines dated July 20, 2026, this reporting obligation is passive: Upstream market participants must provide the reference numbers; downstream actors are not required to proactively request them on their own initiative. A routine substantive review of each individual upstream declaration is not required; the information can be stored as part of existing standard business documentation, such as invoices. However, the legal responsibility for ensuring that the products are indeed deforestation-free remains with them.

SME retailers are exempt from the requirement to submit their own due diligence statement, but must retain supplier information and reference numbers for at least five years from the date they are made available on the EU market and provide them to the authorities upon request.

Micro- or small-scale primary producers generally do not submit a full risk assessment, but only a simplified declaration, provided they source exclusively from low-risk countries or regions.

As a company, how can I go about implementing the EUDR?

A first step is to involve internal stakeholders early on—particularly those from purchasing, sustainability, and quality assurance—to establish a shared understanding of tasks, responsibilities, and risks.

Next, determine to what extent your company is actually affected and which of the four roles (market participant, micro/small primary producer, downstream market participant, trader) applies to you. Not every product containing wood, soy, or other relevant raw materials is automatically subject to the EUDR; a targeted analysis helps prevent unnecessary extra work.

Take advantage of existing opportunities for simplification: Batches with the same origin can be grouped together in a single due diligence statement, and incoming upstream statements can be reviewed on a risk-based basis rather than across the board, and as a downstream market participant, it is generally sufficient to record existing reference numbers via standard business documentation.

Establish clear processes for risk analysis, the collection of geographic data, and documentation—ideally supported by digital systems. And actively seek dialogue with suppliers, because only by working together can traceability throughout the supply chain be ensured.

CONSUST supports you in implementing the EUDR

The EUDR presents companies with new requirements, but it also offers an opportunity to strengthen their sustainability strategy and communicate it transparently, benefiting both your company and your stakeholders. Do you need assistance with preparation and implementation? Contact us for a no-obligation consultation.