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.
Commodities Covered by the EUDR
The EUDR applies to seven commodities and to the derived products listed in Annex I of the Regulation.
Products must not originate from land deforested after 31 December 2020.
Legality
Compliance with the relevant legislation of the country of production.
Due diligence
Where required, submission of a due diligence statement including the geolocation data of the production plot.
When the EUDR Applies
The application dates vary depending on the size of the company. 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.
December 30, 2026
Large and medium-sized operators and traders, as well as micro and small enterprises already covered by the EUTR.
Exercises due diligence, submits a DDS in the Information System, assumes and retains responsibility for compliance, keeps records, communicates DDS reference numbers downstream, and informs the competent authorities.
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
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 notexercise 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 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.
How Trusty can help you to achive EUDR Compliance
Trusty offers a robust, end-to-end traceability platform designed to ensure compliance with the European Union Deforestation Regulation (EUDR).
Data Collection and seamless integrations
Validation and Real-time anomaly detection
Deforestation and social riskanalysis
Due Diligence Management and integrationwith the EU TRACES NT portal
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