What are EUDR covered commodities and deforestation-free products?

The EUDR applies to seven commodities and to the derived products listed in Annex I of the Regulation: cocoa, coffee, soy, oil palm, rubber, cattle, and wood.

What are the three pillars of EUDR compliance?

The three pillars of EUDR compliance are deforestation-free production, legality, and due diligence. Products must not originate from land deforested after 31 December 2020, must comply with the relevant legislation of the country of production, and, where required, must be covered by a due diligence statement including geolocation data.

When does Regulation (EU) 2023/1115 apply?

The application dates vary depending on company size. Large and medium operators are subject to the EUDR from 30 December 2026. Micro and small operators are subject to the EUDR from 30 June 2027, except for micro and small operators already covered by the EU Timber Regulation, for which the application date is 30 December 2026.

EUDR Regulation 2023/1115: Compliance Guide for Companies

Q: What is the EUDR and why does it change the rules for global supply chains?

Regulation (EU) 2023/1115, as most recently amended by Regulation (EU) 2025/2650, governs the placing on the EU market, the making available on the market, and the export of commodities and products linked to deforestation. Its objective is to ensure that they do not contribute to deforestation, forest degradation, biodiversity loss, or greenhouse gas emissions.

Q: What happens in case of EUDR non-compliance?

In case of non-compliance, the EUDR requires Member States to provide for penalties that may include financial penalties, temporary market and export bans, confiscation of products and revenues, and exclusion from public procurement and public funding. Financial penalties may reach at least 4% of the operator's or trader's total annual Union-wide turnover.

What the EUDR Is and Why It Changes the Rules for Global Supply Chains

Regulation (EU) 2023/1115, as most recently amended by Regulation (EU) 2025/2650, governs the placing on the EU market, the making available on the market, and the export of commodities and products linked to deforestation. Its objective is to ensure that they do not contribute to deforestation, forest degradation, biodiversity loss, or greenhouse gas emissions.

Deforestation-free supply chains under the European Union Deforestation Regulation

When Regulation EU 2023/1115 Applies

The application dates vary depending on the size of the company, which must be determined with reference to the financial statements for the 2024 financial year. Although medium-sized enterprises fall within the definition of SMEs — up to 250 employees, €50 million in turnover, and €25 million in total assets — for operational obligations they follow the same deadlines as large companies.

Dicember 30, 2026

For medium-sized and large companies subject to EUDR obligations, the provisions apply after a 42-month transition period starting from the entry into force of the Regulation on 29 June 2023.

June 30, 2027

Micro and small companies subject to EUDR obligations, following the 48-month transition period from the entry into force of the Regulation on 29 June 2023.

EUDR Supply Chain Obligations by Role

The following scheme is based on the EUDR Supply Chain Infographics (3rd Edition) document.

Upstream operator

Exercises due diligence, submits a DDS in the Information System, assumes and maintains responsibility for compliance, keeps the relevant documentation, and informs the competent authorities. Where the upstream operator and the downstream operator are not the same entity, the upstream operator communicates the DDS reference number to the downstream operator.

Upstream micro or small primary operator (MSPO)

Exercises due diligence, submits a one-time simplified declaration, assumes and retains responsibility for compliance, communicates the declaration identifier downstream, and informs the competent authorities.

First downstream operator or trader (non-SME)

Does not exercise due diligence. Registers in the Information System, collects and keeps the required information, including DDS reference numbers or declaration identifiers, informs and verifies where needed.

First downstream operator or trader (SME)

Does not exercise due diligence. Collects and keeps the required information, including DDS reference numbers or declaration identifiers, and informs the competent authorities if information suggests product non-compliance.

Subsequent downstream operator or trader (non-SME)

Does not exercise due diligence. Registers in the Information System, collects and keeps basic information, and informs and verifies where required in case of substantiated concerns

Subsequent downstream operator or trader (SME)

Does not exercise due diligence. Collects and keeps basic information and informs the competent authorities if information suggests that relevant products may be at risk of non-compliance.

What Happens in Case of EUDR Non-Compliance?

In case of non-compliance, the EUDR requires Member States to provide for penalties that may include:

Financial penalties

Fines that are effective, proportionate and dissuasive; for legal persons, the maximum amount must be at least 4% of the total annual turnover generated in the EU.

Temporary market and export bans

Temporary prohibition from placing on the market, making available on the market, or exporting the relevant products.

Confiscation of products and revenues

Confiscation of the relevant products and the revenues obtained from the transaction.

Exclusion from public procurement and public funding

Temporary exclusion from public procurement and from access to public funding, including tenders, grants and concessions.

Turn EUDR Compliance into a Competitive Advantage with Trusty

Trusty offers a robust, end-to-end traceability platform designed to ensure compliance with the European Union Deforestation Regulation (EUDR).

Online and offline data collection with seamless integrations

Validation and Real-time anomaly detection

Deforestation and social risk analysis

Due Diligence Management and integration with the EU TRACES NT portal

Learn More

EU Regulation on Deforestation-free Products (EUDR)

What the EUDR Is and Why It Changes the Rules for Global Supply Chains

EUDR Covered Commodities and Deforestation-Free Products

Cocoa

Coffee

Soy

Oil palm

Rubber

Cattle

Wood

The Three Pillars of EUDR Compliance

Deforestation-free

Legality

Due diligence