Key points at a glance
- The EUDR applies from 30 December 2026 for medium-sized and large companies, and from 30 June 2027 for micro and small companies. A special rule applies to the wood sector, which is covered from 30 December 2026 throughout.
- Affected companies must prove that their products are deforestation-free and legally produced in the country of origin. They must submit a due diligence statement in the EU Information System, with enforcement supported by customs controls at the border.
- A simplification package presented by the European Commission in May 2026 significantly reduces the compliance burden, but does not change the application date. A third postponement is not planned.
What is the EU Deforestation Regulation?
EUDR stands for EU Deforestation Regulation. The legal basis is Regulation (EU) 2023/1115, in force since June 2023 and amended at the end of 2025 by Regulation (EU) 2025/2650.
Its aim is to reduce the EU market’s contribution to global deforestation.
In practice, certain raw materials and derived products may only be placed on the EU market, made available on the EU market or exported if they meet three conditions:
- deforestation-free, meaning not produced on land deforested after 31 December 2020
- legal, meaning produced in accordance with the laws of the country of production
- documented, meaning covered by a due diligence statement
– Why this is a customs topic?
The regulation is not only linked to import. It also applies expressly to export. Both are customs-relevant processes. Companies moving goods across the EU external border should therefore not treat the EUDR as a downstream sustainability task, but as part of the import and export process.
When does the EUDR apply and what is new in 2026?
The application date has been postponed twice. The current deadlines are staggered.
| Company size | Application date |
| Medium-sized and large companies | 30 December 2026 |
| Micro and small companies | 30 June 2027 |
| Micro and small companies in the wood sector | 30 December 2026 |
– Special case: the wood sector
Small and micro companies trading in wood are covered from 30 December 2026, at the same time as large companies. This is because the previous EU Timber Regulation had already imposed comparable obligations on the sector. Wood-processing companies should plan for this earlier date.
– No third postponement
In May 2026, the European Commission presented a simplification package. The main message is that the regulation text will not be reopened and the application date remains 30 December 2026. A third postponement is not planned. Companies should therefore use the remaining time for preparation.
Who is affected and where in the supply chain?
– Operators and traders
The EUDR distinguishes between roles in the supply chain.
- Operators place relevant products on the Union market for the first time or export them. From a customs perspective, this is typically the importer or exporter. They carry the main responsibility.
- Traders make goods available on the market without being the first placing party.
Since the reform at the end of 2025, the obligation to submit the due diligence statement has been concentrated on the first placing party. Downstream actors and larger traders only need to register and may refer to existing statements.
– Role of company size
Company size also determines the depth of obligations. Classification follows the size categories of EU accounting law. In simplified terms, a company is considered large if it has more than 250 employees and either a balance sheet total of more than EUR 25 million or net turnover of more than EUR 50 million. Most micro and small companies have longer deadlines and reduced requirements.
Which goods fall under the EUDR and how can you identify them?
The regulation covers seven commodities and products derived from them:
- cattle, for example beef and leather
- cocoa, for example chocolate
- coffee
- oil palm, for example palm oil and derivatives
- rubber, for example tyres
- soy
- wood, for example furniture and paper
– Annex I: customs tariff codes decide
The products specifically covered are listed in Annex I of the regulation. They are identified by their HS codes, meaning the same customs tariff codes used in customs declarations.
This makes tariff classification the natural starting point for every EUDR assessment. Once a product is classified, the code shows directly whether the product is in scope.
Only the listed code is decisive. A product whose customs tariff code is not listed in Annex I is not covered, even if it contains components made from relevant commodities.
Note on draft changes to product scope
With the May 2026 package, the Commission presented a draft delegated act to adjust the product scope. Proposed changes include:
- Additions such as soluble coffee, certain palm oil derivatives including soap, and frozen bovine tongues
- Removals such as hides, skins and leather of cattle, and retreaded tyres
- Clarification that bamboo, rattan and similar materials are not covered
The act is still a draft. The public consultation ran until early June 2026. Affected companies should monitor the final version.
What obligations does the EUDR create?
– The three steps of due diligence
The core of the regulation is a three-step due diligence process.
- Information collection: Companies must collect data on the product, supplier and origin, including the geolocation of the production plots.
- Risk assessment: Companies must assess whether there is a risk that the product does not meet the EUDR requirements.
- Risk mitigation: Where risks are identified, companies must take mitigation measures until the risk is negligible.
– Geolocation and cut-off date
Geolocation is one of the most demanding elements. For each batch, the geographical coordinates of the production plots must be available. The relevant cut-off date is 31 December 2020. The land must not have been deforested or degraded after that date.
– Due diligence statement and TRACES NT
Once the due diligence obligations have been fulfilled, the first placing party submits a due diligence statement electronically through the EU Information System, TRACES NT. The system generates a reference number that accompanies the consignment through the rest of the supply chain. The EU Information System allows operators to view and manage due diligence statements, including in bulk via API for larger operators.
– Risk classification of producer countries
The intensity of the checks depends on the risk classification of the country of production: low, standard or high. For sourcing from low-risk countries, the requirements are reduced. A full risk assessment and risk mitigation are not required unless there are specific indications of non-compliance.
How does the EUDR affect import, export and customs clearance?
– DDS reference number and customs declaration
This is where the EUDR becomes a customs topic. The due diligence statement and its reference number are not isolated documents. They are linked to the customs declaration.
When relevant goods are released for free circulation or exported, the reference number must be available. The competent authorities, including customs authorities, use the Information System to verify statements and enforce compliance through controls and checks.
– Consequences for customs clearance
If no valid statement is available, or if there are doubts, clearance can be delayed.
The regulation gives authorities provisional measures under Article 23, including:
- temporary suspension of placing the products on the market or exporting them
- seizure of the relevant products
Incorrect or missing EUDR documentation therefore becomes a direct logistics risk, with possible delays, storage costs and supply chain disruption.
All common customs procedures are affected: import, export, transit and customs warehousing. Companies that organise customs processes and EUDR evidence separately risk friction at the point where both processes meet.
– Penalties for non-compliance
Where infringements are identified, penalties can be significant:
- fines of up to 4% of annual EU-wide turnover
- confiscation of goods and revenues
- exclusion from public procurement and public funding for up to twelve months
- temporary prohibition from placing relevant products on the market or exporting them
There is also the publication of final sanction decisions, which can create reputational risk beyond the financial impact.
What was simplified by the reform and simplification package?
– Binding changes since the end of 2025
Regulation (EU) 2025/2650 is already in force. It:
- concentrates the declaration obligation on the first placing party
- introduces a one-off simplified declaration for small and micro primary operators from low-risk countries, instead of a declaration for each shipment
– The May 2026 package
The simplification package from May 2026 adds further measures, some of which are not yet final. It includes four elements:
- a report to the European Parliament and the Council
- updated guidance and revised FAQs
- a draft delegated act on the product scope
- an updated implementing act on the Information System
According to the Commission, the combined simplifications should reduce annual compliance costs by around 75% compared with the original version.
Two points are especially relevant in practice:
- Downstream actors only need to collect standard business data from their direct suppliers. The reference number is only required if the direct supplier is an importer.
- Two central databases should make legality checks easier, covering the laws of producer countries and recognised certifications such as FSC or PEFC.meet.
– EUDR and the EU Omnibus context
The development fits into the broader EU trend towards simplification, also reflected in the Omnibus procedures. For the EUDR, however, the core obligations remain in place. What is being reduced is mainly procedural complexity and the depth of evidence, not the basic objective.
How should companies prepare for the EUDR?
A practical preparation plan can be built around three steps.
- Determine whether you are affected: Check the product range against Annex I using customs tariff codes and monitor the draft delegated act.
- Secure the required data: Clarify early with suppliers who provides which information, especially geolocation data, and set up a reliable sourcing and documentation process.
- Integrate EUDR into customs clearance: Embed the workflow for due diligence statements and reference numbers into customs processes, so the evidence is available at the time of declaration.
As a neutral customs service provider, Gerlach supports affected companies at this interface, from tariff classification and import or export clearance to the management of complex goods flows through the Control Tower.
This helps anchor EUDR compliance where it becomes operational: in the customs process itself.
Conclusion
The EUDR is more than a sustainability requirement. From 30 December 2026, it becomes a fixed part of import and export processes.
Companies trading affected goods should treat it as a customs and logistics topic:
- determine whether their products are in scope using customs tariff codes
- prepare the required data and declarations in time
- integrate both into customs clearance processes
The 2026 simplifications provide room for manoeuvre, but they do not change the deadline. With an experienced customs partner, companies can structure their preparation and reduce friction at the border.
