Reviewed 31 August 2026 · next review 30 November 2026
Which EUDR date applies to you, and what decides it
Size category, establishment date and existing EUTR coverage — three facts that move your deadline by six months and change what you should be doing this quarter.
Last updated · Written and reviewed by Jonatan Tensetti · Tensetti Tools
Reviewed 31 August 2026: large and medium operators, and micro and small operators already covered by the EUTR, use 30 December 2026; other qualifying micro and small operators use 30 June 2027. Product scope, transaction activity, role and transition facts still determine the practical pathway. Annex I is moving: use the current consolidated regulation for today's scope and track C(2026)4920 separately until it is published and enters into force.
| Situation | Application date | Decided by |
|---|---|---|
| Large and medium enterprises | 30 December 2026 | Size category evidence |
| Most micro and small enterprises | 30 June 2027 | Micro/small size and establishment by 31 December 2024 |
| Micro and small businesses already covered by the EUTR | 30 December 2026 | Existing EUTR coverage overrides the later micro/small date |
| Micro or small business established after 31 December 2024 | 30 December 2026 | The later date depends on establishment before that cut-off |
Why the later date is not a reason to wait
The work that takes time is not the filing. It is obtaining geolocation from suppliers who have never been asked, agreeing lot identifiers across purchasing and logistics, and finding a named owner for evidence that today lives in an inbox. Businesses on the June 2027 pathway that start in 2027 will be collecting data from third parties under time pressure.
The date also interacts with your role. A downstream actor with a later date still needs the supplier and buyer records and, where it is the first actor after the upstream operator, the upstream reference — none of which appears by itself.
Backwards plan from your date
| Months before your date | Focus |
|---|---|
| 12+ | Confirm the Annex I code and the role per flow. Fix the size evidence. |
| 9 | Segment suppliers, count plots, agree point-versus-polygon per plot. |
| 6 | Close the geolocation tail; escalate unobtainable plots commercially. |
| 3 | Risk assessment record: decision, reasoning, date, approver. |
| 1 | Information System account, statement owner and deputy, reference handoff. |
Verification note
Re-verified 31 August 2026 against the current European Commission EUDR implementation page, the July 2026 implementation update, Regulation (EU) 2025/2650 and the Commission-adopted delegated act C(2026)4920. Application starts 30 December 2026 for large and medium operators and for micro and small operators already covered by the EUTR, and 30 June 2027 for other qualifying micro and small operators. The revised model places ordinary due-diligence-statement responsibility primarily on first operators, while qualifying micro or small primary operators may use the one-off simplified declaration pathway. Annex I must be checked against the live legal text: C(2026)4920 had been adopted by the Commission but was not yet published with an Official Journal regulation number at this review date, so its proposed product-scope changes are tracked as pending rather than treated as law in force.
No account, no supplier documents, no evidence uploads. Answers stay in your browser.
Primary sources
Reviewed 31 August 2026. Always confirm against the current official text.
- Regulation on deforestation-free products — implementation overview — European Commission. Current application dates, implementation overview and links to Commission resources.
- Commission update on product scope and implementation tools — European Commission. 13 July 2026 Commission update on proposed product-scope changes, the Information System, simplified declarations and the revised operating model. Product-scope changes described there must be checked against the delegated act's current legal status before being treated as effective.
- Consolidated Regulation (EU) 2023/1115 — EUR-Lex. Current consolidated text at the 31 August 2026 review date. Use it for the in-force Annex I baseline and verify whether EUR-Lex has published a later consolidation before making a material decision.
This is a self-service readiness and documentation tool based on the information you provide and the sources listed for assessment version 1.0.0. It is not legal advice, an audit, certification, conformity assessment or an official filing. It does not submit a due diligence statement, validate Annex I classification or geolocation, certify deforestation-free status or determine negligible risk. Verify material decisions with the relevant authority or a qualified adviser.
Frequently asked questions
- When does the EUDR start applying to my company?
- Large and medium enterprises apply the rules from 30 December 2026. Most micro and small enterprises follow on 30 June 2027, unless they were already covered by the EU Timber Regulation, in which case 30 December 2026 applies.
- How is company size decided?
- Size follows the EU accounting definitions based on turnover, balance sheet total and employee numbers. Keep the evidence for the category you claim, because your deadline depends on it.
- Does the later date mean we can wait until 2027?
- Collecting plot geolocation and supplier data is the slow part, and it depends on parties outside your company. Teams that start twelve months out usually finish; teams that start three months out usually escalate.
- Where should we confirm these dates?
- Always confirm against the Commission's current EUDR implementation pages and the regulation text itself. This page is reviewed periodically and links the primary sources it relies on.