EUDR: what the anti-deforestation regulation changes for producers

Regulation (EU) 2023/1115, known as the EUDR for European Union Deforestation Regulation, entered into force on 29 June 2023 and is the most far-reaching text for European agricultural supply chains since the CAP. From 30 December 2025 (SMEs: 30 June 2026), it bans the placing on the European Union market of seven raw materials and their derived products if they originate from land deforested after 31 December 2020. Here is what a producer, importer or distributor needs to have taken on board.

The seven commodities covered

Annex I of the regulation precisely lists the products in scope. The reach is broad: it covers the raw material, but also every processed product that contains it.

• Cattle: fresh, frozen or processed meat; hides and skins; offal.
• Cocoa: beans, butter, powder, and any chocolate or confectionery containing cocoa.
• Coffee: green or roasted, decaffeinated or not, extracts and preparations.
• Palm oil: crude or refined oil, as well as its derivatives (palmitic acid, glycerol, soaps, biodiesel).
• Rubber: natural rubber, and manufactured products (tyres, hoses, gloves).
• Soy: beans, meal, oil, and any animal feed containing soy.
• Wood: logs, sawn timber, panels, paper, cardboard, charcoal, pulp, printed books.

The regulation provides for a review clause in 2025 that could extend the list (maize, sugar cane and pig meat are the most-discussed candidates).

The two cumulative criteria: “deforestation-free” and “legality”

To enter the European market, a product must satisfy two cumulative conditions:

1. Zero deforestation after 31 December 2020: the plot of production must not have been converted from forest after that cut-off date. Article 2 of the regulation refers to the FAO definition of forest (tree canopy cover above 10% over more than 0.5 hectares, potential height of 5 metres). Converting primary forest into a plantation — even a cocoa or coffee plantation — is banned.
2. Legality under the law of the producing country: compliance with land rights, labour law, the rights of indigenous peoples, and locally applicable tax and environmental rules.

The due diligence statement (DDS)

Any operator placing a covered product on the European market for the first time (or exporting it from the EU) must file, before release for free circulation, a Due Diligence Statement (DDS) in the Commission's information system, called TRACES NT. The DDS includes:

• Identification of the operator and the product (HS code).
• The quantity, the country of production, and — critically — the geolocation coordinates of every plot of origin.
• A statement on honour attesting that due diligence has been exercised and that the products meet both criteria above.

For holdings larger than 4 hectares, the geolocation must take the form of a GeoJSON polygon; below that, a single GPS point is sufficient. This is the hardest obligation to implement, as it reaches all the way back to the farm, sometimes 4 or 5 links upstream of the European operator.

The 2025-2026 timeline

The timeline was pushed back a year by amending regulation (EU) 2024/3234, published at the end of 2024. The effective deadlines are:

• 30 December 2025: entry into application for large and medium-sized companies (more than 250 employees or turnover above €50m).
• 30 June 2026: entry into application for micro and small companies (SMEs within the meaning of EU recommendation 2003/361).

Wood placed on the market before entry into application remains covered by the previous EUTR regulation until stocks are exhausted.

The country-classification system

The Commission will publish, no later than six months before entry into application, a classification of countries into three categories: low risk, standard risk, high risk. Customs checks will be proportional to that classification:

• High risk: at least 9% of operators and 9% of quantities checked annually.
• Standard risk: at least 3% of operators.
• Low risk: at least 1% of operators, with a simplified DDS procedure.

Penalties

Article 25 of the regulation lists the penalties applicable in the event of non-compliance. They are deliberately heavy and proportional to company size:

• Administrative fineof up to 4% of the operator's annual turnover in the European Union.
• Confiscation of non-compliant products and the revenue drawn from their sale.
• Temporary exclusion from public procurement and European public funding for up to 12 months.
• Temporary ban on placing products on the market for repeat offenders.

What to do in 2026?

For a producer or importer still unprepared, four work streams should be prioritised:

1. Map the supply chain down to the plot. This is the longest step: allow 6 to 18 months for a cocoa or coffee supply chain.
2. Collect the GPS coordinates of the farms of origin. Specialised SaaS tools (including VeraTrace for French supply chains) automate this collection.
3. Cross-reference the coordinates against satellite deforestation datasets (Global Forest Watch, Hansen, JRC GFC2020) to confirm the absence of post-2020 forest conversion.
4. Set up the DDS filing process in TRACES NT and train customs teams.

Conclusion

The EUDR is one of the most demanding regulations of the European Green Deal, and its implementation will deeply restructure several global supply chains. Operators who got ahead by digitising their traceability will benefit from a lasting advantage: the marginal cost of the DDS will be near-zero for them, while it will remain structurally high for latecomers. The transparency forced by the EUDR also reshuffles competition: farms that produce cleanly, and can prove it plot by plot, will become preferred suppliers.