Reviewed 31 August 2026 · next review 30 November 2026
What is the EU Deforestation Regulation?
Regulation (EU) 2023/1115 links access to the EU market to deforestation-free production, legality in the country of production and the due-diligence or traceability duties that apply to the actor and product flow.
Last updated · Written and reviewed by Jonatan Tensetti · Tensetti Tools
The three product conditions
A relevant product placed on or made available on the EU market, or exported from it, has to satisfy the conditions in Article 3. Deforestation-free means the relevant commodity was not produced on land deforested after 31 December 2020 and, for wood, that harvesting did not induce forest degradation after that date. The product must also have been produced in accordance with the relevant legislation of the country of production. The operational due-diligence, declaration or traceability work then depends on the actor's role and the pathway created by the current rules.
The seven commodities — and a changing product annex
The seven commodities remain cattle, cocoa, coffee, oil palm, rubber, soya and wood. Scope does not stop at those commodity names: Annex I identifies the actual relevant products by customs classification. That is why the current CN/HS code and the current Annex I text matter more than an intuition that a product is "made from wood" or "contains rubber". Use the product-scope guide to check the annex rather than relying on examples.
The annex has already changed. Regulation (EU) 2025/2650 removed the former Chapter 49 entry for printed books, newspapers, pictures and other printed paper products with effect from 26 December 2025. On 13 July 2026 the Commission adopted a further delegated regulation, C(2026)4920, proposing additional additions, removals and technical exclusions — including changes affecting cattle hides/leather and several rubber entries. As of 31 August 2026 EUR-Lex still presents that act as a Commission-adopted delegated regulation without an Official Journal regulation number. Treat those July changes as pending until the act is published and enters into force; check the live Annex I before making a scope decision.
Roles decide what you owe
| Role | Who it fits | Core duty |
|---|---|---|
| Operator | You first place a relevant product on the EU market, or export it from the EU. | Perform the applicable due diligence and, for the ordinary operator pathway, submit a due diligence statement before placing or exporting. |
| Micro or small primary operator | A qualifying micro or small first operator that produces the relevant products itself in the same low-risk country in which it is established. | A one-off simplified declaration pathway may apply rather than an ordinary statement per consignment; the qualifying conditions still have to be established. |
| Downstream operator | You place a relevant product that has already been placed on the market by an operator upstream. | Under the December 2025 simplification, generally no own DDS; keep the required traceability information and, where applicable, the upstream statement reference and verification evidence. |
| Trader | You make a relevant product available on the market without being the first operator for that product flow. | Keep the required supplier and customer information. Additional registration or verification duties depend on the trader pathway and size under the current rules. |
One company can hold more than one role across different flows — for example, importing one product and distributing another that was already placed on the EU market. Map the role per transaction and product flow, not once at company level. The role guide walks through the distinctions.
When it applies
Large and medium operators use 30 December 2026. Micro and small operators that were already covered by the EU Timber Regulation also use 30 December 2026. Other qualifying micro and small operators use 30 June 2027. The date is not a substitute for resolving the product and role first. Check the date pathway.
What the ordinary due-diligence pathway involves
- Information. Assemble the information required for the product flow, including description, quantity, country of production, geolocation, production dates or ranges and counterparties.
- Risk assessment. Assess the risk that the relevant products fail the Article 3 conditions using the applicable criteria and evidence.
- Risk mitigation. Where risk is not negligible, obtain further information or evidence and take proportionate measures until the legal condition for proceeding is met.
- Statement. Where the ordinary operator pathway requires a DDS, submit it in the Information System before placing or exporting and retain/transfer the reference information required by the downstream chain.
Do not force downstream operators, traders or qualifying micro/small primary operators into this four-step filing description when the current rules give them a different pathway. Resolve the role first.
Where teams get stuck
The recurring blockers are usually data and ownership rather than the wording of the regulation: product classifications that were never recorded, geolocation data that cannot be tied to a lot, supplier evidence with no owner, and a transaction that changes the organisation's role. These issues take longer to repair than filling in a form, so surface them before the application date.
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.
- Regulation (EU) 2025/2650 — EUR-Lex. In-force December 2025 amendment covering revised operator/trader obligations, application-date provisions, the micro/small primary-operator route and removal of the former Annex I Chapter 49 printed-products entry.
- EUDR Information System resources — European Commission. Official implementation page linking the current Information System and related technical resources.
- 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.
- FAQ on EUDR implementation — European Commission. Commission implementation FAQ page refreshed in August 2026 and available in EU languages.
- Commission Delegated Regulation C(2026)4920 — Annex I amendment — EUR-Lex / European Commission. Adopted by the Commission on 13 July 2026. At the 31 August 2026 review date EUR-Lex still displayed an unnumbered delegated regulation rather than a published Official Journal act. Track this source for status changes before applying its proposed Annex I additions, removals and technical exclusions.
No account, no supplier documents, no evidence uploads. Answers stay in your browser.
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.