EUDR: The Deforestation Regulation for Importers

Anyone importing coffee, cocoa, soy, wood products or leather goods into the EU will soon feel the EU Deforestation Regulation (EUDR) in every order. From 30 December 2026, large and medium-sized companies may only place the covered commodities on the market if they can prove the goods do not originate from land deforested after 2020. For importers, that means origin, geolocation and legality must be documented without gaps, otherwise the shipment stays at customs.

In brief: The EUDR (Regulation (EU) 2023/1115) bans the import and trade of seven commodities and their derived products from deforested areas. The cut-off date for deforestation-free status is 31 December 2020. After a second postponement, it applies to large and medium-sized companies from 30 December 2026 and to micro and small enterprises from 30 June 2027. The core obligation is a due diligence statement with the geolocation of the plots of origin. Breaches carry fines of up to 4% of EU-wide annual turnover.

What is the EU Deforestation Regulation (EUDR)?

The EU Deforestation Regulation (EUDR) is an EU-wide market-access law: it makes the sale of certain commodities and their derived products in the EU conditional on no forest having been cleared to produce them. Unlike earlier rules, it reverses the burden of proof: it is not the authority that must prove a breach, but the company that must demonstrate the integrity of every shipment before placing it on the market. The legal basis is Regulation (EU) 2023/1115.

The background is an uncomfortable finding: European consumption is among the largest drivers of global deforestation. According to a 2021 WWF report, the EU was responsible for roughly 16% of global tropical deforestation embodied in international trade in 2017, the second-largest contributor after China (WWF, 2021). With the regulation, Brussels aims to keep products from deforestation off the European market.

The regulation rests on three pillars. First, products must be deforestation-free, meaning they do not originate from land cleared after 31 December 2020. Second, production must be legal, in line with the laws of the country of origin, from environmental rules and labour rights to the protection of indigenous peoples. Third, a due diligence statement must be submitted, confirming that any remaining risk is negligible.

When does the EUDR apply?

Few EU rules have been postponed as often as the EUDR. Originally due to take effect at the end of 2024, it was delayed by a year and then a second time at the end of 2025. With amending Regulation (EU) 2025/2650, published in the Official Journal of the EU on 23 December 2025, the following deadlines now apply:

For most importers with meaningful trade volumes, 30 December 2026 is the date that counts. Relying on repeated postponements is risky: while the Commission had to review the effect of the simplifications by 30 April 2026, there is no sign of a fundamental retreat from the regulation. The groundwork (supplier data, geolocation, internal processes) typically takes several months. Starting only in autumn 2026 leaves little room to breathe.

Which products and commodities are covered?

The EUDR covers seven commodities and a broad list of products derived from them. What matters is not whether you import the raw commodity itself, but whether it is contained in your product.

Which specific article is covered follows from the customs codes (HS codes) in Annex I of the regulation. One detail from the second postponement: books, newspapers and printed matter (HS heading "ex 49") were removed from Annex I. Importers should therefore map their range against the current Annex I at the level of individual customs codes. This task is closely tied to the broader import requirements for 2026.

What obligations do importers have under the EUDR?

The heart of the EUDR is the due diligence obligation. It runs in three steps: gather information, assess risk, mitigate risk. Only once the risk is deemed negligible may the goods be placed on the market.

Gather information. For each shipment you must record, among other things, the geolocation of all plots of production: precise points for small parcels, polygons for larger areas. Quantities, supplier details and proof of legal production come on top. This data originates deep in the supply chain, often from producers you have no direct contact with. This is where the biggest practical hurdle lies.

Assess and mitigate risk. Based on the data, you assess whether a deforestation or legality risk exists. Where there are well-founded doubts, additional measures are needed, such as independent audits, spot checks or supplementary evidence. A structured supplier audit thus becomes a central tool of EUDR compliance.

Submit the due diligence statement. The statement is filed via the EU information system (the central EUDR register) and receives a reference number that accompanies the goods through the supply chain. An important simplification from Regulation (EU) 2025/2650: only the first operator placing the goods on the market, typically the importer who first brings the goods onto the EU market, must submit a full due diligence statement. Downstream traders simply refer to the existing reference number. For importers, this actually pushes responsibility further to the front: you stand at the start of the chain and carry the full burden of proof.

Who carries which obligation depends on the role in the supply chain:

In our sourcing projects in the Far East, a pattern emerges: the geolocation data often already exists at the producer, but is not digitally prepared. Those who use a direct line to the manufacturer usually obtain it without delivery delays, while importers without that contact regularly struggle to gather the data.

How does the EUDR country benchmarking work?

So that the effort is not equally high for every country of origin, the EUDR uses a country benchmarking system. The European Commission assigns each producer country to one of three risk levels: low, standard or high. This classification governs both the depth of your due diligence and how frequently authorities run checks.

In May 2025, the Commission published the first country list. Only Belarus, Myanmar, North Korea and Russia were initially classified as high-risk, and most of the world falls into the low or standard categories. Even so, classification is no reason for importers to relax: even at low risk, geolocation and proof of origin remain mandatory; only the risk assessment itself becomes leaner.

What penalties apply for breaches?

The EUDR provides for substantial penalties. These are set by the member states but must be "effective, proportionate and dissuasive", and the regulation sets a clear framework:

• Fines of up to 4% of the company's EU-wide annual turnover

• Confiscation of the products concerned and of the revenue earned from them

• Temporary exclusion from public tenders and public funding

• Trade ban on the products concerned

For an import-heavy business, the turnover threshold can quickly become existential. Add to that the reputational damage when goods are blocked or seized. Compliance here is not just box-ticking but active risk management.

What should importers do now?

The good news: the second postponement buys importers time, but only if they use it. From our experience, this is the most sensible sequence of steps:

• Screen your range. Map your articles against Annex I at the level of customs codes. Which products fall under the EUDR, and which do not?

• Map the supply chain. For each covered article, clarify where the commodity is produced and whether your suppliers can deliver geolocation data. A systematic supplier evaluation helps to assess your suppliers' data readiness.

• Close data gaps. Talk to producers early. Sourcing reliable geodata from deep in the supply chain is the most time-critical point.

• Set up processes. Define who creates the due diligence statement, how risks are assessed, and how evidence is stored in an audit-proof way.

• Create transparency. An end-to-end view of origin, quantities and documents decides whether the EUDR becomes routine or a constant strain.

Frequently asked questions (FAQ)

When does the EUDR apply?

The EUDR applies to large and medium-sized companies from 30 December 2026 and to micro and small enterprises from 30 June 2027. These deadlines come from the second postponement under Regulation (EU) 2025/2650 of December 2025. Whether a company counts as large is determined as of the cut-off date of 31 December 2024.

Which products fall under the EUDR?

The EUDR covers seven commodities (cattle, cocoa, coffee, oil palm, rubber, soy and wood) and products derived from them, such as leather, chocolate, tyres, furniture, paper and palm oil. Whether a specific article is covered is decided by its customs code (HS code) under Annex I. Pure wooden packaging that merely serves to transport other goods is excluded.

Does the EUDR also apply to small companies (SMEs)?

Yes, but only from 30 June 2027 and with relief measures. Micro and small primary producers from low-risk countries only need a one-time, simplified declaration. The core obligations, deforestation-free status and proof of origin, nevertheless apply to SMEs too.

What if a supplier cannot provide geolocation data?

Without the geolocation of the plots of production, no valid due diligence statement can be submitted, and the goods may not be placed on the market. Importers must then obtain the missing data together with the supplier after the fact, or switch to a source that can prove origin. The earlier this is resolved, the less often the data gap turns into a shipment stop.

How does the EUDR differ from supply chain due diligence laws (LkSG)?

The German supply chain act (LkSG) requires large companies to address human-rights and environmental risks across their entire supply chain. The EUDR is narrower and product-specific: it concerns seven commodities and ties market access to deforestation-free origin alone, regardless of company size. Supplier data can be collected jointly for both obligations.

Conclusion: implement the EUDR early and stay able to deliver

The EUDR makes deforestation-free sourcing a precondition for market access. Those who work through their range, supply chain and geodata early turn the obligation into a manageable process, instead of coming under pressure shortly before 30 December 2026. The biggest hurdle is rarely the regulation itself, but reliable access to origin data from deep in the supply chain.

This is exactly where Line Up comes in. For over 30 years we have sourced products from the Far East, with our own branch office on site and direct access to around 70% of our manufacturers. This proximity to the supply chain is invaluable under the EUDR: those who know the producers can reliably obtain geolocation data and proof of origin. With our SCD Dashboard, we make supply chains visible in real time. This is the basis for consolidating origin data and preparing due diligence statements without last-minute stress. If you are rethinking your import routes anyway, our guide to sea freight from China to Germany offers further pointers on documentation along the transport chain.

Want to know which of your imports fall under the EUDR and how to build the evidence in time? 👉 Arrange a no-obligation consultation. We combine sourcing experience with digital supply chain transparency so that the Deforestation Regulation stays manageable for you.

Note: This article reflects the status as of June 2026 and does not constitute legal advice. The applicable versions of Regulation (EU) 2023/1115 and amending Regulation (EU) 2025/2650 are authoritative. Current guidance for Germany is published by the [Federal Office for Agriculture and Food (BLE)](https://www.ble.de/DE/Themen/Wald-Holz/Entwaldungsfreie-Produkte/Aktuelles/Aktuelles.html).