In this page we provide you with an overview of the EUDR and its key obligations.
EUDR refers to the European Union Deforestation Regulation 2023/1115. Amendments were made in December 2025 by Regulation (EU) 2025/2650, and are included in this overview.
The EUDR replaces the EU Timber Regulation (EUTR), enlarging both its obligations and the product scope.
The EUDR aims to minimize the EU’s contribution to deforestation and forest degradation and reducing greenhouse gas emissions and biodiversity loss. The regulation applies products made from 7 key commodities that are the greatest contributor to deforestations. The 7 commodities are: cattle, cocoa, coffee, oil palm, rubber, soya, and wood.
Which products are in scope?
The EUDR obligations apply to all products mentioned in Annex I of the Regulation. The products are scoped using their CN (Combined Nomenclature) or HS (Harmonised System) customs codes.
Since December 2025, EUDR does not apply to products covered by CN code 49, which applies to printed products like books, newspapers, etc.
The obligations apply to products that enter the EU market or are exported from the EU.
and which are not in scope?
Some products are excluded based on their CN code, even though they may contain relevant commodities. For example, this is the case for leather car seats, or soap containing palm oil.
Since December 2025, EUDR does not apply to products covered by CN code 49, which applies to printed products like books, newspapers, etc.
Products that are produced entirely from material “that has completed its lifecycle” (waste) are excluded from the scope of the EUDR, as the use of recycle materials is encouraged by the EU.
Packaging material such as wooden packing cases, boxes, crates or pallets that is only used to support, protect, or carry other products that are placed on the market is not included in the EUDR.
What are the obligations?
The EUDR defines a number of company categories in relation to EUDR products. These are listed below:
| EUDR role | Who falls in this category? |
| Operator | Places products on the EU market, like an importer |
| First downstream operator | Places on the market or exports relevant products made using relevant products, all of which are covered by a due diligence statement or by a simplified declaration. Its direct supplier is an operator or micro & small primary operator. |
| Downstream operator | Places on the market or exports relevant products made using relevant products, all of which are covered by a due diligence statement or by a simplified declaration. |
| Trader | Makes products available on the market but does not modify them. Like a distributer or a retailer |
| First downstream Trader
|
Makes products available on the market but does not modify them. Its direct supplier is an operator or micro & small primary operator. |
| Micro & Small primary operator | Operator who is a natural person or meets Art. 3(1) and (2) of Directive 2013/34/EU and is established in a EUDR Low Risk Country. Companies in this category have themselves grown, harvested, obtained from, or raised on relevant plots of land, or, as regards cattle, on establishments located in that. A small forestry enterprise that produces wood from its own forest falls into this category |
Companies have different obligation depending on their category and size.
The operator is required to assure, with no or negligible risk, that the product was produced with without deforestation, forest degradation and in accordance with the relevant legislation. Further information on how to assure these is available in the next sections of this page. The operator needs to submit on the EU platform Traces a Due Diligence Statement (DDS). Micro & Small primary operator have the same obligations, but shall instead submit a one-time Simplified Statement on Traces.
Downstream operators and traders, shall keep track of some basic supply chain details and, in case they are not SME, also register themselves to Traces. If they supply directly from an operator, they shall also keep record of the DDS or Simplified Declarations connected to that number.
This below table summarizes some of the key requirements:
| EUDR role | Key traceability obligations |
| Operator | · Conducts Due Diligence
· Submits DDS |
| First downstream operator | · Keep track of supply chains details
· Track the DDS/ Simplified Declaration number · Register to Traces (if not SME) |
| Downstream operator | · Keep track of supply chains details
· Register to Traces (if not SME) |
| Trader | · Keep track of supply chains details
· Register to Traces (if not SME) |
| First downstream Trader
|
· Keep track of supply chains details
· Track the DDS/ Simplified Declaration number · Register to Traces (if not SME) |
| Micro & Small primary operator | Submit Simplified Declaration |
Due Diligence Statement & Simplified Declaration
Operators shall issue a Due Diligence Statement and submit it to the EU platform Traces. The document declares that the operators has performed the relevant due diligence.
All operators who conclude that the product complies with the EUDR, must submit a DDS (with all reference numbers) in which they confirm that due diligence was carried out and that no or only a negligible risk was found.
The contents of the Due Diligence statement is detailed in Annex II of the EUDR.
The Statement shall be kept for 5 years from the date of placing the product on the market.
Micro and Small primary operators shall instead submit a one-time Simplified Declaration on Traces. The content of the Simplified Declaration is detailed in Annex II of Regulation (EU) 2025/2650. It shall contain: supplier information, product information and estimated annual quantity of the product brought to the market, geolocation of all relevant plots of land or their address and a declaration that proper due diligence was performed to avoid deforestation, forest degradation and produce legally.
EUDR Due Diligence
Operators shall be able to demonstrate how information was gathered, what criteria were used for the risk assessment and how decisions on risk mitigation were taken. This is done through a due diligence system.
Due diligence means providing evidence that products are both:
- Deforestation-free: produced on land that was not subject to deforestation after 31 December 2020
- Legal: compliant with all relevant applicable laws in force in the country of production.
The due diligence procedure requires the fulfilment of the following three elements and is complemented by reporting requirements.
- Information – Access to information describing the commodities species and products, country of production, geolocation of all plots of land of production sites, quantity, details of the supplier and information on compliance with national legislation and customs regulation.
- Risk assessment – Assess the risk of deforestation in the supply chain, based on the information mentioned above and considering criteria set out in the regulation.
- Risk mitigation – If the assessment shows that there is a risk of deforestation in the supply chain, that risk shall be mitigated by requiring additional information and verification from the supplier and introducing adequate and proportionate policies, controls and procedures to manage effectively the risks of non-compliance.
Operators shall be able to demonstrate how information was gathered, what criteria were used for the risk assessment and how decisions on risk mitigation were taken.
The collected information shall be kept for 5 years from the date of placing the product on the market.
Geographical data
To check against deforestation, operators need to have geographical data about where the EUDR commodities used in the product comes from. With this information, one can demonstrate that there is no deforestation on that specific location.
The EUDR accepts two types of geographical data:
- Address of the plot of land or establishment where the commodity is sourced. Only micro and small primary operators can use this option.
- Geographical coordinates: can be used by all operators.
Via air photos, satellite images or mobile phones, widespread and free-to-use digital applications (e.g. Geographic Information Systems (GIS)) geolocation coordinates can be collected. It is important that the information is linked with geotags and time stamps. The EU supports companies with the EU Observatory monitoring tool, but there are other monitoring satellite tools available. Operators must fulfil the obligation to verify that the geolocation information is correct. Any product or commodity covered by this regulation whose geographical data has not been collected and submitted correctly is prohibited to be placed on the EU market.
Deadlines
The Regulation (EU) 2023/1115 (EUDR) on deforestation and forest degradation entered into force on 29 June 2023 and replaces the Timber Regulation (EU) 995/2010.
Medium and large-sized companies will have till 30 December 2026 to comply with the EUDR. For micro or small enterprises, this deadline is six months later: 30 June 2027.
How ProductIP helps you with the EUDR
At ProductIP we can help you with your EUDR compliance journey.
We do that by giving you and your suppliers access to a smart form to gather all data you need to comply with the EUDR obligations. The form adapts as the user enters information, so to show only the EUDR requirements that apply to their product.
The smart form also helps you with the EUDR due diligence: a risk model automatically tells where risks are more likely and prompts the supplier to show evidence on how they are mitigating them.
If you approve the work of the supplier, the system will automatically create a Due Diligence Statement, opening the EU market to your product.
More information
Guidance document from the European Commission for Regulation (EU) 2023/1115 on Deforestation-Free Products.
Find out How to comply with the Deforestation Regulation.
Frequently Asked Questions (FAQ) about the Deforestation Regulation.
Get access to ProductIP’s Compliance Tuesday content on this topic
