EUDR · Plain-Language Overview
EUDR decoded — a clear read for effective compliance.
Regulation (EU) 2023/1115 in plain terms — what it requires, who it applies to, and the two deadlines that actually matter if you export cocoa, coffee, palm oil, or gold-adjacent commodities into the EU.
SME exporters
Cooperatives
Trade bodies
Licensed buying companies
UPDATED · 15 Jul 2026
READ TIME · 7 min
COVERS · Regulation (EU) 2023/1115
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What it is
Why EUDR exists
The EU Deforestation Regulation — Regulation (EU) 2023/1115 — requires that specific commodities placed on or exported from the EU market are deforestation-free, produced legally, and covered by a due diligence statement. It replaced the older EU Timber Regulation and extended the same logic to a much wider set of commodities.
The premise is simple: EU demand for commodities like cocoa, coffee, and palm oil has historically been linked to forest loss in producing countries. EUDR shifts the burden of proof onto the companies placing goods on the EU market — they now have to demonstrate a shipment is deforestation-free, not just claim it.
Who it affects
Operator roles, explained
EUDR obligations depend on where you sit in the supply chain. The regulation does not treat every company the same way — your role determines your paperwork.
First Operator
Places goods on the market first
The entity that first imports or places the relevant commodity onto the EU market. Carries the full due diligence obligation — geolocation, legality check, risk assessment, and DDS filing.
Downstream Operator
Processes already-verified goods
Uses products that already carry a valid DDS reference further down the chain. Can rely on the upstream statement, but still holds obligations if combining or repackaging products.
Micro/Small Primary Operator
SME-scale first placement
A first operator that qualifies as micro or small under EU thresholds. Same core obligations, but eligible for the simplified declaration route under the Simplification Package.
Trader
Makes goods available, doesn't place first
Sells or distributes products already placed on the market by someone else. Obligations are lighter than an operator's, but non-SME traders still carry due diligence responsibility.
Scope
What commodities are covered
Seven commodity groups, plus their derived products — chocolate and cocoa butter count the same as raw cocoa beans; furniture and paper count the same as raw wood.
🍫Cocoa
☕Coffee
🌴Palm Oil
🐄Cattle
🌱Soy
🧪Rubber
🪵Wood
The line in the sand
The cut-off date: December 31, 2020
Any plot of land deforested or degraded after December 31, 2020 is permanently out of scope for EUDR-compliant trade — regardless of when the regulation itself entered into force. This is retroactive by design: it closes the obvious loophole of clearing land now and claiming compliance later.
This is also why geolocation matters more than it first appears. A plot's history has to be checked against satellite forest-cover data going back to the cut-off date, not just its current state — which is why farm-level polygon data, not just a country-of-origin label, sits at the center of every due diligence statement.
The obligation
What due diligence actually requires
01 · Geolocation
Plot-level coordinates
Polygon data for plots over 4 hectares; point coordinates for smaller plots. Every batch of commodity has to trace back to the specific land it came from.
02 · Legality
Compliant with origin-country law
Production must comply with the relevant laws of the country of production — land use, environmental protection, labor rights, and third-party rights including indigenous and community land rights.
03 · Risk Assessment
Evaluate before you file
Operators must assess deforestation and legality risk for each shipment, factoring in the country's benchmark tier, before a due diligence statement can be filed with confidence.
04 · DDS Filing
Submitted through TRACES
The Due Diligence Statement is filed through the EU's TRACES system before the goods are placed on the market, generating a reference number that follows the shipment downstream.
Timing
The two deadlines that matter
Large & Medium Operators
Dec 30, 2026
Full due diligence obligations apply from this date for large and medium-sized operators and traders placing goods on the EU market.
Micro & Small Primary Operators (Non-Timber)
Jun 30, 2027
SME-scale primary operators outside the timber category get a longer runway — but the underlying data requirements are the same, so waiting until the deadline is the expensive option.
Country risk
Benchmarking: no shortcuts yet
EUDR sorts countries and regions into low, standard, or high-risk benchmark tiers, which is meant to determine how intensively your shipments get checked. A low-risk classification means fewer spot-checks and lighter administrative load.
Current Status
All countries: Standard Risk
As of this writing, the benchmarking exercise has not differentiated any country into the low-risk tier — every origin, including Côte d'Ivoire and Cameroon, sits at standard risk by default. There is no country-based shortcut available today, regardless of what a given corridor's actual track record looks like.