The EUDR Regulation Explained

This guide is based on (EU) 2023/1115 and its amendments current as of September 2026 (EU 2024/3234, EU 2025/2650 and the 2026 delegated/implementing acts). Provided for compliance reference only; not legal advice.

① Legal history: a regulation postponed three times

DateLegal instrumentKey point
29 June 2023(EU) 2023/1115 enters into forceEUDR formally enters into force, replacing the EU Timber Regulation (EUTR); originally to apply from 30 Dec 2024
19 December 2024(EU) 2024/3234First postponement: application delayed by 12 months (Member States and industry cited information-system and readiness gaps)
19 December 2025(EU) 2025/2650Second postponement + simplification: application delayed by another 12 months; roles redefined into "operator / downstream operator / micro-primary operator", concentrating the DDS obligation on the first company placing products on the EU market
13 July 2026Delegated act + implementing actAnnex I product scope updated (see "Scope"); rules for the EUDR information system (based on TRACES) established; simplification package (multilingual guidance + FAQs) completed
Bottom line: the current application dates are 30 December 2026 (large and medium enterprises + all downstream operators and traders) and 30 June 2027 (micro and small enterprises). The EU has postponed twice, but the substance of the regulation is unchanged — the delay is preparation time, not a cancellation.

② Scope: seven commodities + Annex I derived products

Seven commodities: cattle, cocoa, coffee, oil palm (palm oil), rubber, soy and wood.

Annex I lists derived products by HS code. Directly relevant to wood product exporters:

  • Chapter 44: sawn wood (4407/4408), fibreboard/particle board/plywood (4410-4412), wooden kitchenware (4419), wood marquetry/sculptures (4420), picture frames (4414), wooden flooring (4409), charcoal (4402), wood chips (4401), etc.
  • Chapter 94: seats with wooden frames (9401), other wooden furniture (9403), etc.
  • Chapters 47/48: pulp, paper and paperboard products
  • Chapter 40: new pneumatic rubber tyres, rubber hoses and other rubber products
Key changes from the July 2026 delegated act:
  • Removed: bovine hides/leather, retreaded tyres, soy used exclusively for sowing, vulcanised rubber products, conveyor belts, aircraft/motor-vehicle seats, printed matter (books, newspapers, printed pictures)
  • Added (applying from 30 Dec 2027): soluble coffee, certain palm-oil derivatives, frozen bovine tongues
  • Explicit exemptions: samples and testing products, waste/scrap/second-hand goods, packaging materials, excipients in medicinal products

Note: with leather removed, leather shoes and leather goods are in principle no longer covered by EUDR. However, if raw hides are not placed on the market as an independent product but declared along with cattle-related products, customer requirements may still apply. Scope is ultimately determined by Annex I HS codes.

③ The three substantive requirements (Article 3)

Relevant products may be placed on the EU market or exported from it only if all three of the following are met; otherwise placement is prohibited:

  1. Deforestation-free: the land used has not been subject to deforestation or forest degradation since 31 December 2020 (degradation = conversion of primary/naturally regenerating forest into plantation forest). For "mixed" products (e.g. pulp from multiple sources), every input batch must be traceable to plots post-dating that cutoff.
  2. Produced under the laws of the country of production: covering land use rights, forestry and environmental law, third-party rights (human rights / indigenous peoples), labour rights, tax, anti-corruption, trade and customs, and IFC performance standards on security services.
  3. A Due Diligence Statement (DDS) has been submitted: via the EU information system, obtaining a statement reference number.

Geolocation requirements (Article 9) — the hardest part in practice

  • Geographic coordinates of all relevant plots must be provided in WGS-84 (GPS) or an approved geodetic system, with latitude/longitude to at least 6 decimal places
  • Plots larger than 4 hectares require polygon coordinates rather than a single point
  • For cattle products, coordinates of the establishment where the animals were kept suffice
  • Where upstream cooperatives/suppliers cannot provide plot data, companies may collect alternative information and aggregate it — but the risk-assessment duty remains with the company filing

④ Who does what? (roles as amended by 2025/2650)

RoleDefinitionCore obligations
Operator (non-SME)The company first placing relevant products on the EU market or exporting themFull due diligence (information → risk assessment → risk mitigation) + file the DDS, and pass the reference number downstream
Downstream operatorA company further processing or placing on the market / exporting goods made from inputs already covered by a DDS (new category)No new DDS required; collect and retain upstream DDS reference numbers; non-SMEs must register in the information system
Micro/small primary operatorsNatural persons or micro/small enterprises in low-risk countries placing on the market / exporting products they themselves produced or sourcedFile a single simplified declaration (new Annex III)
TraderResellers in the supply chainNon-SMEs must register; collect and retain DDS numbers and supplier/customer information
What this means for Chinese exporters: your EU customer (the importer) is the "operator" — they file the DDS. But they can only file it if you provide: the HS-code mapping of your product, plot geolocation of raw materials, and legality evidence. That is why Chinese factories must prepare in advance.

Record-keeping: all roles must retain supplier/customer information for 5 years.

⑤ The due diligence process and DDS filing (Articles 8-12, 14)

1
Information collection (Art. 9)
Product description (HS code, quantity, country of production), plot geolocation, supplier details, and conclusive and verifiable evidence of deforestation-free and legal production.
2
Risk assessment (Art. 10)
Assess the risk of non-compliant products in the supply chain, based on the country risk level: verify source plots, mixed sourcing, complex supply chains, corruption indices, indigenous-rights conflicts, contradictions between satellite imagery and field data, etc.
3
Risk mitigation (Art. 11)
Where risk is not negligible: require additional supplier audits, independent third-party verification, site visits, satellite monitoring, supplier capacity building; if still inadequate, the product must not be placed on the market.
4
File the DDS (Art. 14)
Submit via the EU information system (based on TRACES), obtain the reference number and verification token that accompany the goods; customs will match the DDS against the shipment.

⑥ Country risk benchmarking and check rates (Article 16)

Risk levelBasisImpact on companies
Low riskCommission assessment: limited forest loss/degradation, cooperation arrangements with the EU, etc.Simplified due diligence (may rely on collected information, no need per batch)
Standard riskDefault levelFull due diligence
High riskHigh deforestation rates, agricultural/forestry expansion, serious governance issues, etc.Full due diligence + enhanced on-the-ground checks by Member States

Member State authorities check companies at rates tied to the level (high risk 9%, standard 3%, low risk 9% but simplified checks). The benchmarking list is published and updated by the Commission — although Chinese companies are outside the EU, exports are traced back to source-country plots; timber, palm oil etc. from high-risk regions will face stricter scrutiny.

⑦ Penalties (Article 25) — severe

  • Fines: a maximum of at least 4% of the operator's annual EU-wide turnover
  • Confiscation: of the non-compliant products and of revenues generated
  • Temporary exclusion: up to 12 months' ban from placing relevant products on the market, and from public procurement and public funding
  • Market exclusion: entry in the compliance database affecting future customs clearance

Moreover, private citizens and NGOs can file complaints, and EU citizens and environmental organisations can seek judicial review under the Aarhus Convention — there are many channels through which supply chain compliance gaps get exposed and reported.

⑧ EUDR vs EUTR (the old EU Timber Regulation)

DimensionEUTR (replaced)EUDR (current)
Product coverageWood and wood products onlyWood + cattle/cocoa/coffee/oil palm/rubber/soy — seven commodities
Legality requirementLegal harvesting onlyLegal + deforestation-free / no forest degradation (31 Dec 2020 baseline)
Plot traceabilityNo mandatory plot coordinatesMandatory geolocation / polygons
DeclarationInternal due diligence system (weak DDS concept)Electronic DDS via the central information system, reference number follows the goods
PenaltiesSet by each Member StateFines of at least 4% of EU turnover + confiscation + exclusion
Trade directionImportsPlacing on the EU market + exports from the EU

⑨ FAQ

Q1: We are a factory in China, outside the EU. Does EUDR really apply to us?

Yes — "indirectly but fatally". The DDS is filed by your EU customer (the importer), but they need you to provide plot coordinates, legality evidence and batch traceability. If you cannot, they cannot complete their DDS, and they will switch suppliers. EUDR effectively transfers compliance cost and responsibility down the whole supply chain, to Chinese factories.

Q2: Can the forestry bureau's harvesting permit be used as coordinate evidence?

The harvesting permit is an important legality document, but EUDR requires plot-level WGS-84 coordinates (polygons for large plots). Many older Chinese permits contain only boundary descriptions or local coordinate systems (e.g. CGCS2000 Gauss-Krüger projection), which must be converted to WGS-84 lat/long, with GPS field measurements where necessary. This is precisely the real weakness of most Chinese factories.

Q3: We buy imported raw materials (Russian/Southeast Asian timber, Brazilian pulp). Whose responsibility is it?

As part of the supply chain you must pass plot information and legality evidence downstream (to the EU customer); if upstream suppliers cannot provide it, you must either switch suppliers or help them build traceability — EU customers only accept chains that ultimately trace to the plot.

Q4: Are wooden furniture items (9403) really in scope? What about leather?

Wooden furniture is in Annex I. Leather (bovine hides, leather goods) was removed from scope by the July 2026 delegated act. Mixed-material furniture (e.g. wood frame + fabric) is judged on its wooden part and remains a relevant product.

Q5: Is "EUDR certification" the same as FSC certification?

No. Voluntary schemes like FSC/PEFC can serve as one input to risk assessment, but they cannot replace EUDR due diligence — EUDR is a legal obligation; certification is only supporting evidence. Conversely, an EUDR traceability system also helps with FSC CoC audits.

Q6: It has been postponed again to end-2026 — can we wait a bit longer?

Quite the opposite: collecting plot coordinates involves many upstream farmers/forest farms and is the most time-consuming, least controllable part of the chain, typically taking 6-12 months. Your EU customers must file DDS from 30 December 2026, so they will demand data from Chinese suppliers well before that. Starting now is just in time; starting next year most likely means lost orders.

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