Last reviewed 2 Aug 2026 · Regulation (EU) 2023/1115
EUDR compliance: what applies, and when
EUDR applies to large operators from 30 December 2026 and to micro and small enterprises from 30 June 2027. It covers seven commodities, requires geolocation coordinates for every plot of land behind a product, and carries fines of at least 4% of EU-wide turnover. Products are non-compliant if the land was deforested after 31 December 2020.
About 124 days until the large-operator deadline (30 December 2026). Geolocation data has to come from your suppliers’ suppliers, so the collection work is the long pole — it does not start when the deadline arrives.
Who has to comply, and by when
As of August 2026, EUDR applies to large operators and traders from 30 December 2026 and to micro and small enterprises from 30 June 2027, under the amending Regulation (EU) 2025/2650.
As of August 2026, EUDR covers seven commodities, of which oil palm (34.0%) and soya (32.8%) together account for roughly two thirds of EU-driven deforestation.
Large operators and traders
Companies above the EU’s micro/small thresholds that place the relevant commodities on the EU market or export them from it.
Micro and small enterprises
Including natural persons. The extra six months was granted to reduce the administrative burden and allow the EU IT system to mature.
Most guidance online is out of date. EUDR has been postponed twice. Pages still citing 30 December 2024 or 30 December 2025 are quoting superseded law. The current dates come from Regulation (EU) 2025/2650, published in the Official Journal on 23 December 2025.
Non-EU companies are in scope whenever their products are placed on the EU market — this is a market-access rule, not an EU-establishment rule.
The seven commodities in scope
Percentages are each commodity’s share of EU-driven deforestation, as stated in Recital 38 of the regulation. Palm oil and soya alone account for roughly two thirds.
Link to any row: xgesg.info/eudr-compliance-guide#cocoa
| Commodity | Share of EU-driven deforestation | Example products |
|---|---|---|
| Oil palm | 34% | Palm oil, palm kernel oil, derivatives in food and cosmetics |
| Soya | 32.8% | Soybeans, soya flour, oil and meal — including animal feed |
| Wood | 8.6% | Timber, pulp, paper, printed books, furniture, charcoal |
| Cocoa | 7.5% | Cocoa beans, paste, butter, powder, chocolate |
| Coffee | 7% | Roasted and unroasted coffee, husks and skins |
| Cattle | 5% | Live cattle, beef, hides and leather |
| Rubber | 3.4% | Natural rubber, tyres, gloves, industrial rubber goods |
What due diligence actually requires
Four obligations. The first is the one that takes months.
Collect information — including geolocation
You need the country of production, quantity, supplier details, and geolocation coordinates of every plot of land where the commodity was produced. The regulation specifies latitude and longitude to at least six decimal places. This is the requirement most companies underestimate: it reaches back through the supply chain to the plot, not the supplier.
Assess the risk
Evaluate whether the products risk being non-compliant, using the country's risk classification, presence of forests in the area, prevalence of deforestation, and the complexity of the supply chain.
Mitigate the risk
Where the risk is more than negligible, take mitigation measures — additional information, independent audits, supplier surveys — until it is negligible.
Submit a due diligence statement
Before placing products on the market or exporting them, submit an electronic due diligence statement in the EU information system, taking responsibility for compliance.
Why geolocation is the hard part. The coordinates must identify the plot of land, to at least six decimal places of latitude and longitude. For a chocolate manufacturer that means every cocoa farm; for a furniture importer, every forest parcel. That data sits several tiers upstream, often with suppliers who have never been asked for it.
Country risk changes how much work you do
The Commission classifies producer countries into three tiers. The tier determines how far your obligations extend.
Low risk
Simplified due diligence — collect information, but risk assessment and mitigation are not required.
Standard risk
Full due diligence: information, risk assessment and mitigation.
High risk
Full due diligence, plus enhanced scrutiny by competent authorities.
Penalties for non-compliance
Article 25. Unlike CSRD — which sets no EU-wide fine at all — EUDR fixes a floor that every member state must meet.
Fines from 4% of EU turnover
Article 25 requires each member state to set a maximum fine of at least 4% of the operator's or trader's total annual Union-wide turnover. That is a floor, not a ceiling — states may go higher, and fines can be raised further to exceed any economic benefit gained from the breach.
Confiscation of products and revenues
Authorities can seize the non-compliant products themselves and the revenues earned from selling them.
Exclusion from public procurement
Temporary exclusion from public procurement processes, public funding, grants and tenders, for up to 12 months.
Ban on placing or exporting
A temporary prohibition on placing the relevant products on the EU market or exporting them from it.
Sources
- Regulation (EU) 2023/1115 — full text (EUR-Lex) (opens in new window)
- Postponement to December 2026 — European Commission (opens in new window)
- Council press release on the targeted revision (opens in new window)
- Commission guidance on deforestation-free products (opens in new window)
Methodology
Every date, figure and obligation on this page was checked against the primary sources listed above — the regulation’s full text on EUR-Lex, the amending Regulation (EU) 2025/2650, and the Commission’s own guidance. Nothing appears here that is not traceable to a cited source; commodity shares come from Recital 38 of the regulation itself. The application dates get the closest scrutiny, because EUDR has been postponed twice and most published guidance still quotes a superseded deadline. Figures were last checked on 2 Aug 2026 — confirm against the linked primary source before relying on any of them for a compliance decision.
Last reviewed 2 Aug 2026. EUDR has been postponed twice already — check the linked primary sources before relying on any date here for a compliance decision. This page is information, not legal advice. EUDR is one of the regulations tracked in the XG regulation database.
Next step
Talk to Carolina about EUDR
Carolina Ramirez — ESG Expert in Latin America
XG tracks 850 regulations across 119 jurisdictions.
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The geolocation data is the project
Most EUDR programmes fail on supplier data, not on paperwork. If you are working out how far up your chain you can actually see, that is the conversation to have now rather than in December.
This guide is general information about published regulation, not legal, financial or regulatory advice, and reading it does not create a professional relationship. Dates and obligations change without notice — confirm against the primary sources linked above, and take advice on your own circumstances, before acting. See our terms.
XG Regulation Register · 850 regulations · 119 jurisdictions · Checked 2 Aug 2026