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EU Deforestation Regulation (EUDR)

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This page provides a detailed overview of the EU Deforestation Regulation (EUDR), including its scope, timelines, due diligence requirements and recent amendments. It is intended for organisations and practitioners seeking a deeper understanding of how the regulation works in practice and how it continues to evolve. 

 

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What is the EUDR?

The EU Deforestation Regulation aims to reduce the EU’s contribution to global deforestation and forest degradation by regulating the placing on the market and export of certain agricultural and forestry commodities. The regulation introduces mandatory due diligence requirements to ensure that covered products:

  • are not linked to deforestation or forest degradation after 31 December 2020; and
  • are produced in accordance with the laws of the country of production

In December 2025, the EU agreed to amend the EUDR. These amendments include a one-year postponement of the application date and adjusted obligations for certain downstream actors and small and micro primary operators.

 

Why the EUDR was introduced

The EUDR responds to evidence linking agricultural expansion and forest degradation to climate change and biodiversity loss.

Between 1990 and 2020, 420 million hectares of forest were lost due to deforestation. (FAO)

 

Agriculture and forestry account for around 23% of anthropogenic greenhouse gas emissions, with agricultural production alone contributing approximately 12%. (IPCC)

 

Deforestation is responsible for around 11% of greenhouse gas emissions. (IPCC)

 

By addressing these drivers, the regulation seeks to reduce environmental impacts associated with EU consumption patterns. 

 

Who does the EUDR apply to?

The EUDR applies to operators, downstream operators and traders that place relevant commodities or derived products on the EU market or export them from the EU. Covered commodities include soy, cattle, oil palm, wood, cocoa, coffee and natural rubber. Organisations must be able to prove that these products do not originate from recently deforested land, do not contribute to forest degradation and are produced legally.

If you are unsure how the regulation applies to your organisation, our free self-assessment tool can help clarify roles and obligations. 
>> Access our EUDR Scoping Tool

 

When does the EUDR apply?

The regulation applies from 30 December 2026 for large and medium-sized organisations. An extended deadline of 30 June 2027 applies to operators that qualified as small or micro undertakings before 30 December 2024, subject to specific conditions. This extension:

  • does not apply to downstream operators or traders
  • does not apply to wood products previously covered by the EU Timber Regulation (EUTR).

 

What happens to the EUTR?

The EUDR will replace the EU Timber Regulation (EUTR) once it becomes applicable. However, the EUTR will continue to apply for a transitional period of three years for wood products that:

  • were harvested before the EUDR entered into force (29 June 2023); and
  • are placed on the EU market on or after the EUDR becomes applicable (30 December 2026).

 

Commodities and products in scope

Soy
Cattle
Palm oil
Wood
Cocoa
Coffee
Rubber

The EUDR targets seven commodities identified by the EU based on consumption levels and deforestation risk: soy, cattle, oil palm, wood, cocoa, coffee and natural rubber.

For each commodity, the regulation specifies covered products through EU customs codes listed in Annex I. Products not listed in Annex I are generally outside the scope of the regulation.

 

Cattle

  • Live cattle (0102 21, 0102 29)
  • Meat of cattle, fresh or chilled (ex 0201)
  • Meat of cattle, frozen (ex 0202)
  • Edible offal of cattle, fresh or chilled (ex 0206 10)
  • Edible cattle livers, frozen (ex 0206 22)
  • Edible cattle offal (excluding tongues and livers), frozen (ex 0206 299
  • Other prepared or preserved meat, meat offal, blood, of cattle (ex 1602 50)
  • Raw hides and skins of cattle (fresh, or salted, dried, limed, pickled or otherwise preserved, but not tanned, parchment-dressed or further prepared), whether or not dehaired or split (ex 4101)
  • Tanned or crust hides and skins of cattle, without hair on, whether or not split, but not further prepared (ex 4104)
  • Leather of cattle, further prepared after tanning or crusting, including parchment-dressed leather, without hair on, whether or not split, other than leather of heading 4114 (ex 4107)

 

Cocoa

  • Cocoa beans, whole or broken, raw or roasted (1801)
  • Cocoa shells, husks, skins and other cocoa waste (1802)
  • Cocoa paste, whether or not defatted (1803)
  • Cocoa butter, fat and oil (1804)
  • Cocoa powder, not containing added sugar or other sweetening matter (1805)
  • Chocolate and other food preparations containing cocoa (1806)

 

Coffee

  • Coffee, whether or not roasted or decaffeinated; coffee husks and skins; coffee substitutes containing coffee in any proportion (0901)

 

Oil Palm

  • Palm nuts and kernels (1207 10)
  • Palm oil and its fractions, whether or not refined, but not chemically modified (1511)
  • Crude palm kernel and babassu oil and fractions thereof, whether or not refined, but not chemically modified (1513 21)
  • Palm kernel and babassu oil and their fractions, whether or not refined, but not chemically modified (excluding crude oil) (1513 29)
  • Oilcake and other solid residues of palm nuts or kernels, whether or not ground or in the form of pellets, resulting from the extraction of palm nut or kernel fats or oils (2306 60)
  • Glycerol, with a purity of 95 % or more (calculated on the weight of the dry product) (ex 2905 45)
  • Palmitic acid, stearic acid, their salts and esters (2915 70)
  • Saturated acyclic monocarboxylic acids, their anhydrides, halides, peroxides and peroxyacids; their halogenated, sulphonated, nitrated or nitrosated derivatives (excluding formic acid, acetic acid, mono-, di- or trichloroacetic acids, propionic acid, butanoic acids, pentanoic acids, palmitic acid, stearic acid, their salts and esters, and acetic anhydride) (2915 90)
  • Stearic acid, industrial (3823 11)
  • Oleic acid, industrial (3823 12)
  • Industrial monocarboxylic fatty acids; acid oils from refining (excluding stearic acid, oleic acid and tall oil fatty acids) (3823 19)
  • Industrial fatty alcohols (3823 70)

 

Rubber

  • Natural rubber, balata, gutta-percha, guayule, chicle and similar natural gums, in primary forms or in plates, sheets or strip (4001)
  • Compounded rubber, unvulcanised, in primary forms or in plates, sheets or strip (ex 4005)
  • Unvulcanised rubber in other forms (e.g. rods, tubes and profile shapes) and articles (e.g. discs and rings) (ex 4006)
  • Vulcanised rubber thread and cord (ex 4007)
  • Plates, sheets, strips, rods and profile shapes, of vulcanised rubber other than hard rubber (ex 4008)
  • Conveyer or transmission belts or belting, of vulcanised rubber (ex 4010)
  • New pneumatic tyres, of rubber (ex 4011)
  • Retreaded or used pneumatic tyres of rubber; solid or cushion tyres, tyre treads and tyre flaps, of rubber (ex 4012)
  • Inner tubes, of rubber (ex 4013)
  • Articles of apparel and clothing accessories (including gloves, mittens and mitts), for all purposes, of vulcanised rubber other than hard rubber (ex 4015)
  • Other articles of vulcanised rubber other than hard rubber, not elsewhere specified in chapter 40 (ex 4016)
  • Hard rubber (e.g. ebonite) in all forms including waste and scrap; articles of hard rubber (ex 4017)

 

Soya

  • Soya beans, whether or not broken (1201)
  • Soya bean flour and meal (1208 10)
  • Soya-bean oil and its fractions, whether or not refined, but not chemically modified (1507)
  • Oilcake and other solid residues, whether or not ground or in the form of pellets, resulting from the extraction of soya-bean oil (2304)

 

Wood

  • Fuel wood, in logs, in billets, in twigs, in faggots or in similar forms; wood in chips or particles; sawdust and wood waste and scrap, whether or not agglomerated in logs, briquettes, pellets or similar forms (4401)
  • Wood charcoal (including shell or nut charcoal), whether or not agglomerated (4402)
  • Wood in the rough, whether or not stripped of bark or sapwood, or roughly squared (4403)
  • Hoopwood; split poles; piles, pickets and stakes of wood, pointed but not sawn lengthwise; wooden sticks, roughly trimmed but not turned, bent or otherwise worked, suitable for the manufacture of walking sticks, umbrellas, tool handles or the like; chipwood and the like (4404)
  • Wood wool; wood flour (4405)
  • Railway or tramway sleepers (cross-ties) of wood (4406)
  • Wood sawn or chipped lengthwise, sliced or peeled, whether or not planed, sanded or end-jointed, of a thickness exceeding 6 mm (4407)
  • Sheets for veneering (including those obtained by slicing laminated wood), for plywood or for other similar laminated wood and other wood, sawn lengthwise, sliced or peeled, whether or not planed, sanded, spliced or end-jointed, of a thickness not exceeding 6 mm (4408)
  • Wood (including strips and friezes for parquet flooring, not assembled) continuously shaped (tongued, grooved, rebated, chamfered, V-jointed, beaded, moulded, rounded or the like) along any of its edges, ends or faces, whether or not planed, sanded or end-jointed (4409)
  • Particle board, oriented strand board (OSB) and similar board (for example, waferboard) of wood or other ligneous materials, whether or not agglomerated with resins or other organic binding substances (4410)
  • Fibreboard of wood or other ligneous materials, whether or not bonded with resins or other organic substances (4411)
  • Plywood, veneered panels and similar laminated wood (4412)
  • Densified wood, in blocks, plates, strips or profile shapes (4413)
  • Wooden frames for paintings, photographs, mirrors or similar objects (4414)
  • Packing cases, boxes, crates, drums and similar packings, of wood; cable-drums of wood; pallets, box pallets and other load boards, of wood; pallet collars of wood (not including packing material used exclusively as packing material to support, protect or carry another product placed on the market) (4415)
  • Casks, barrels, vats, tubs and other coopers’ products and parts thereof, of wood, including staves (4416)
  • Tools, tool bodies, tool handles, broom or brush bodies and handles, of wood; boot or shoe lasts and trees, of wood (4417)
  • Builders’ joinery and carpentry of wood, including cellular wood panels, assembled flooring panels, shingles and shakes (4418)
  • Tableware and kitchenware, of wood (4419)
  • Wood marquetry and inlaid wood; caskets and cases for jewellery or cutlery, and similar articles, of wood; statuettes and other ornaments, of wood; wooden articles of furniture not falling in Chapter 94 (4420)
  • Other articles of wood (4421)
  • Pulp and paper of Chapters 47 and 48 of the Combined Nomenclature, with the exception of bamboo-based and recovered (waste and scrap) products
  • Seats (other than those of heading 9402 ), whether or not convertible into beds, and parts thereof, of wood (ex 9401)   
    Wooden furniture, and parts thereof (9403 30 , 9403 40 , 9403 50 , 9403 60 and 9403 91)
  • Prefabricated buildings of wood (9406 10)

Note: The “ex” prefix indicates that only part of the corresponding customs code is included in Annex I of the EUDR. A given code may cover a wider range of products, of which only certain products fall within the scope of the regulation. 

Composite Products

For products made from more than one relevant commodity, only the component classified as the main commodity is subject to EUDR requirements.

For example, in a chocolate bar, only the cocoa-based ingredients fall within the scope.

 

Products outside the scope of the EUDR

EU customs code not listed in Annex 1

Any EU customs code (CN codes) not listed in Annex 1 of the regulation is considered outside the scope of the EUDR.

Products at the end of their lifecycle

The EUDR does not apply to products made entirely from material that has reached the end of its lifecycle and would otherwise be discarded as waste, except in cases where the material is a by-product of a manufacturing process that involved material not classified as waste (as defined in Article 3, point 1 of Directive 2008/98/EC).

Products at the end of their lifecycle

The EUDR does not apply to products made entirely from material that has reached the end of its lifecycle and would otherwise be discarded as waste. An exception applies where the material is a by-product of a manufacturing process that involved material not classified as waste (as defined in Article 3, point 1 of Directive 2008/98/EC).

Packaging

Annex I of the EUDR, specifies that:

  • due diligence requirements apply to any wood/paper packaging falling under an Annex I customs code, when placed on the market or exported as a product in its own right; and
  • packaging falling under CN code 4415 is exempt when used solely as packing material to support, protect or carry another product placed on the market.

The EUDR FAQ provides an update on packaging:

  • Packaging material used to support, protect or carry another product is outside scope, regardless of the CN code under which it falls, including paper and cardboard packaging (e.g., CN 4819).  
  • User Manuals accompanying shipments are not relevant products unless purchased independently.
  • Selling or renting used packaging material (such as second-hand pallets) is not subject to the EUDR.
  • Empty used packaging already used for this purpose and traded within closed-loop systems is outside the scope.
  • Where used packaging is repaired and sold, only new relevant materials used in the repair are subject to due diligence and require a new DDS.

 

Disclaimer
The information and guidance provided on this webpage are for informational purposes only and do not constitute legal, financial, or professional advice. Preferred by Nature makes no representations or warranties, express or implied, regarding the accuracy, completeness, or suitability of the information contained herein. Preferred by Nature is not liable for the use of, or reliance on, the information provided,  nor for any loss arising from such reliance. Responsibility for compliance with the EUDR or any other applicable legislation remains solely with the entity subject to legal obligations.

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Deforestation vs forest degradation 

The regulation defines clear thresholds for deforestation and forest degradation.

"Deforestation-free" means that products must not contain, be fed with, or be made using commodities from land deforested after 31 December 2020. ‘Deforestation’ is defined as the conversion of forest to agricultural use, whether human-induced or not. For wood-based products, additional requirements apply to ensure that harvesting has not caused forest degradation after this date.

“Forest degradation” is defined using FAO  terminology and includes structural changes to forest cover, such as the conversion of primary or naturally regenerating forests into plantation forests.

Compliance with the legislation of the country of production is assessed across eight categories:

  1. land use rights
  2. environmental protection
  3. forest-related regulations including forest management and biodiversity conservation, where directly related to wood harvesting,
  4. third parties’ rights,
  5. labour rights,
  6. human rights protected under international law,
  7. the principle of free, prior and informed consent, including as set out in the United Nations Declaration on the Rights of Indigenous Peoples,
  8. tax, anti-corruption, trade and customs regulations

 

Due diligence requirements

Organisations that place relevant commodities or products on the EU market, or export them from the EU, are considered Operators. Operators must implement a due diligence system as prescribed by the regulation. This includes procedures and measures to ensure that products are deforestation-free and produced in accordance with the country's laws.

Operators must collect supply chain information, assess the risks of non-compliance, and take appropriate risk mitigation measures. Products may only be placed on the EU market or exported once they are assessed as posing no or negligible risk in relation to deforestation-free and legal production requirements.

Operators are also required to report publicly on their due diligence activities on an annual basis.

 

Country Benchmarks and simplified due diligence requirements

The European Commission will establish a centralised database classifying countries as low, standard or high risk based on deforestation indicators.

Operators sourcing from 'low-risk' countries may apply simplified due diligence. However, risks related to mixing or indirect sourcing must still be assessed. The intensity of enforcement will vary according to country risk classification.

 

Certification and third-party schemes

The EUDR recognises that certification and third-party verified schemes can support risk assessment and mitigation. However, such schemes do not replace an operator’s responsibility under the regulation and must be assessed for their scope, credibility and relevance to EUDR requirements.

 

Different requirements for different EU actors

Responsibilities under the EUDR vary depending on the size of the organisation and its role in the supply chain. 

 

Operators

Operators are organisations that place relevant products on the EU market or export them from the EU. This includes organisations that import products into the EU, as well as those that produce them within the EU, for example by growing commodities such as wood, coffee or soy, or by raising cattle.

Under the EUDR, operators are required to exercise due diligence to ensure that the products they place on the market are deforestation-free or, in the case of wood, free from forest degradation, and that they have been legally produced in accordance with the applicable legislation of the country of production.

To meet these obligations, operators must:

  • collect the information required under Article 9 of the EUDR,
  • assess the risk of non-compliance based on that information, taking into account the risk assessment criteria set out in Article 10, and
  • mitigate any identified risks in line with Article 11.

To exercise due diligence effectively, operators must have a due diligence system in place. This system consists of documented procedures describing how the organisation collects information, carries out risk assessments and implements risk mitigation measures.

To demonstrate that due diligence has been exercised, operators must submit a due diligence statement to the EU Information System before placing a relevant product on the EU market or exporting it.

 
 

Micro and small primary operators

Micro and small primary operators are organisations that place relevant products on the EU market or export them where those products have been grown, harvested or raised by the organisation itself.

Like all operators, micro and small primary operators are required to exercise due diligence to ensure that their products are deforestation-free and legally produced.

However, because these operators must be established in countries classified as low risk, simplified due diligence applies. This means they are not required to carry out a formal risk assessment or implement risk mitigation measures. Instead, their due diligence obligations focus on collecting the information required under Article 9 of the EUDR and confirming compliance with the core requirements of the Regulation.

Micro and small primary operators are not required to submit a due diligence statement. Instead, they may submit a simplified due diligence declaration to the Information System, which involves less extensive information requirements than a full due diligence statement.

 
 

Downstream operators and traders

Downstream operators and traders are subject to reduced obligations under the EUDR.

Before placing a relevant product on the market, exporting it or making it available, they must collect basic information about their suppliers, including the supplier’s name, address and email contact details. In addition, where a downstream operator or trader is the first downstream actor in the supply chain, meaning that their direct supplier is an operator, they must also collect and retain the reference number of the due diligence statement or the identifier of the simplified due diligence declaration.

All of this information must be retained for a period of five years.

Non-SME downstream operators and traders are subject to additional requirements. They must register in the Information System and, if they become aware of substantiated concerns indicating potential non-compliance, they are required to verify that due diligence was properly exercised by the initial operator.

 

Categories of undertakings: must not exceed the limits of at least two of the three following criteria (large undertakings must exceed the limits of at least two):

Micro-undertakings

  • balance sheet total: EUR 450 000
  • net turnover: EUR 900 000
  • average number of employees during the financial year: 10

Small undertakings

  • balance sheet total: EUR 5 000 000 - 7 500 000
  • net turnover: EUR 10 000 000 - 15 000 000
  • average number of employees during the financial year: 50

Medium-sized undertakings

  • balance sheet total: EUR 25 000 000
  • net turnover: EUR 50 000 000
  • average number of employees during the financial year: 250

Large undertakings

  • balance sheet total: EUR 25 000 000
  • net turnover: EUR 50 000 000
  • average number of employees during the financial year: 250
 
Unsure if the EUDR applies to your company? Use our self-assessment tool to help you determine your obligations.
>> Access our EUDR Scoping Tool

 

Traceability and geolocation requirements 

Operators must be able to trace products back to the plots of land where they were produced or harvested. For plots larger than four hectares, polygon data is required. Smaller plots may be represented by a single coordinate point.

The European Commission is developing a central Information System to manage due diligence statements and customs processes.

 

Disclaimer
The information and guidance provided on this webpage are for informational purposes only and do not constitute legal, financial, or professional advice. Preferred by Nature makes no representations or warranties, express or implied, regarding the accuracy, completeness, or suitability of the information contained herein. Preferred by Nature is not liable for the use of, or reliance on, the information provided, nor for any loss arising from such reliance. Responsibility for compliance with the EUDR or any other applicable legislation remains solely with the entity subject to legal obligations.


Info sheet

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EUDR Ready: Navigating FSC & PEFC standards for a deforestation-free supply chain Webinar Estonian Online 17 - Completed
EU Deforestation Regulation (EUDR): Bridging challenges and solutions Seminar Czech Brno, Czechia 10 - Completed
FSC og PEFC sporbarhedscertificering (Chain of Custody - CoC) Seminar Danish Hørning, Denmark 28 - Completed
Meeting EU Deforestation Regulation (EUDR) requirements for the coffee sector Seminar English Addis Ababa, Ethiopia 15 - Completed
Navigating the EUDR with practical solutions for Indonesia’s supply chain Webinar Bahasa Indonesia Online 30 - Completed
FSC Controlled Wood Expert Course Expert course English Jurmala, Latvia 27 - Completed
EUDR: Get ready with our overview, updates and solutions Webinar Japanese Online 17 - Completed
FSC Chain of Custody Expert Course Expert course English Minnesota, USA 29 - Completed
FSC Forest Management Expert Course Expert course Spanish Argentina 27 - Completed
FSC Chain of Custody Expert Course Expert course Spanish Argentina 21 - Completed
EU Deforestation Regulation: Unpacking the latest updates and solutions Webinar Simplified Chinese Online 08 - Completed
FSC Forest Management Expert Course Expert course English Montreal, Canada 25 - Completed
EUDR: Understanding implications for US companies Webinar English Online 13 - Completed
FSC Chain of Custody Expert Course Expert course English Toronto, Canada 12 - Completed
FSC Chain of Custody Expert Course Expert course Simplified Chinese China 05 - Completed
EU Deforestation Regulation (EUDR): Implications for the agricultural sector Webinar Spanish Online 20 - Completed
FSC Forest Management Expert Course Expert course English Berlin, Germany 19 - Completed
FSC Chain of Custody Expert Course Expert course English Berlin, Germany 30 - Completed
Implications of the new EU Deforestation Regulation (EUDR) for the forestry sector Webinar Spanish Online 17 - Completed
FSC Chain of Custody Expert Course Expert course English Bangalore, India 12 - Completed
FSC Chain of Custody Expert Course Expert course English Minneapolis, Minnesota, USA 28 - Completed
FSC Forest Management Expert Course Expert course English Jurmala, Latvia 20 - Completed
Sustainability in Practice: EUDR & Carbon Footprint Management Seminar Estonian Tallinn, Estonia 16 - Completed
Sustainability in Practice - EUDR & Carbon Footprint Management Seminar Latvian Rīga, Latvia 15 - Completed
Sustainability in Practice - EUDR & Carbon Footprint Management Seminar Lithuanian Vilnius, Lithuania 13 - Completed
FSC Forest Management Expert Course Expert course English Beijing, China 06 - Completed
FSC Forest Management Expert Course Expert course English Beijing, China 06 - Completed
FSC Forest Management Expert Course Expert course Spanish Concepción, Chile 02 - Completed
FSC Controlled Wood Expert Course Expert course English Jurmala, Latvia 26 - Completed
EU Deforestation Regulation (EUDR): Business implications and impact Webinar Simplified Chinese Online 22 - Completed
FSC Forest Management Expert Course Expert course Spanish Medellín, Colombia 14 - Completed
EUDR & the Future of Forest-risk Commodities Procurement Seminar, Webinar Japanese Tokyo, Japan 12 - Completed
FSC Controlled Wood Expert Course Expert course English Online 05 - Completed
FSC Forest Management Expert Course Expert course English Jurmala, Latvia 29 - Completed
How Scientific Testing can support companies to comply with Due Diligence requirements of the EUDR? Webinar English Online 28 - Completed
How Scientific Testing can support the enforcement of the EUDR? Webinar English Online 21 - Completed
EU Deforestation Regulation (EUDR): Business implications and compliance Seminar Simplified Chinese Shanghai, China 20 - Completed
Complying with the new EU Deforestation Regulation (EUDR): A practical workshop for timber businesses Seminar Vietnamese Ho Chi Minh City, Viet Nam 13 - Completed
EUDR and FSC Policy to Address Conversion & Remedy Framework – What will it mean for Malaysian companies? Seminar English Sabah, Malaysia 09 - Completed
EUDR and FSC Policy to Address Conversion & Remedy Framework – What will it mean for Malaysian companies? Seminar English Sarawak, Malaysia 08 - Completed
EUDR and FSC Policy to Address Conversion & Remedy Framework – What will it mean for Malaysian companies? Seminar English Kuala Lumpur, Malaysia 06 - Completed
EU Deforestation Regulation (EUDR): Implications for the agricultural sector Webinar Online Completed
Clone of Soluciones Basadas en la Naturaleza: Curso de Restauración de Ecosistemas y Proyectos de Carbono Expert course Cercedilla, Spain Completed
Informationsdag FSC og PEFC sporbarhedscertificering Seminar Danish Denmark Completed
Soluciones Basadas en la Naturaleza: Curso de Restauración de Ecosistemas y Proyectos de Carbono Expert course Cercedilla, Spain Completed
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