Who must comply with EUDR?
EUDR has no size threshold. It asks what you place on the EU market, not how large you are or where you are established — and that reaches a chocolate manufacturer, a furniture retailer, a tyre importer and a Brazilian soya exporter by different routes.
EUDR applies to any operator or trader placing oil palm, soya, wood, cocoa, coffee, cattle or rubber — or products derived from them — on the EU market, or exporting them from it. Large operators and traders must comply from 30 December 2026; micro and small enterprises and natural persons from 30 June 2027. Non-EU producers and exporters are in scope whenever their goods reach the EU market. Size affects the weight of the obligation, not whether it applies.
Four routes into scope
As an operator placing an in-scope product on the EU market for the first time — the heaviest position, because the due diligence statement sits with you.
As a trader further down the chain, with lighter duties for SMEs but an obligation to keep and pass on information.
As an exporter taking in-scope goods out of the EU — export is covered, not only import.
As a non-EU producer or exporter whose goods reach the EU market. Establishment outside the Union changes who in the chain files, not whether the rule applies.
Derived products
Where this usually goes wrong
Businesses often screen for the seven commodities and stop. The scope also covers products derived from them: chocolate, furniture, leather, paper, printed books, tyres. A company that has never bought cocoa can be in scope through confectionery.
Screen at commodity level through your bill of materials, not at purchase-order level.
What in-scope status requires
The due diligence statement is the visible obligation. The larger cost is geolocation: latitude and longitude for every plot of land where the commodity was produced, to at least six decimal places.
That data sits several tiers upstream, with producers who may not have been asked for coordinates before. Lead time, not effort alone, is often the binding constraint — which makes the December 2026 date significant.
Questions people actually ask
- Is there a size exemption from EUDR?
- No. Size affects the weight of the obligation and the deadline — micro and small enterprises have until 30 June 2027 rather than 30 December 2026 — but not whether the regulation applies.
- Does EUDR apply to companies outside the EU?
- Yes, whenever their products are placed on the EU market or exported from it. It is a market-access rule rather than an establishment rule.
- What is the EUDR deadline?
- 30 December 2026 for large operators and traders, 30 June 2027 for micro and small enterprises and natural persons. These dates come from Regulation (EU) 2025/2650; guidance citing 2024 or 2025 dates refers to superseded law.
Still not sure what binds you?
XG tracks obligations like these across 119 jurisdictions.