EUDR: deforestation rules for importers
Which products the EU Deforestation Regulation covers, who files the due diligence statement, and the application dates as amended in December 2025.
The EU Deforestation Regulation, Regulation (EU) 2023/1115, covers cattle, wood, cocoa, soy, palm oil, coffee and rubber. It also covers products made from them such as leather, chocolate, tyres and furniture. As amended in December 2025, it applies to large and medium operators from 30 December 2026. It applies to micro and small operators from 30 June 2027. In-scope products may be placed on the EU market only if they are deforestation-free, legally produced and covered by a due diligence statement. The operator that first places the product on the market files that statement.
For an importer, the regulation arrives at the border. The statement’s reference number goes into the customs declaration when the goods are released for free circulation.
Which products fall under the EUDR?
The European Commission lists seven commodities: cattle, wood, cocoa, soy, palm oil, coffee and rubber. Some of their derived products are covered too, and the Commission names leather, chocolate, tyres and furniture as examples.
Coverage is set by the product list in the regulation, not by the commodity alone. A product that contains one of the commodities is in scope only if it is on that list. The check is made product by product.
The scope is also growing. The Commission states that new products added by Commission Delegated Regulation (EU) 2026/2102 “will become subject to the Regulation from 30 December 2027.” The additions include soluble coffee, certain palm oil derivatives and frozen cattle tongues.
When does the EUDR apply?
The application dates were postponed twice, in December 2024 and December 2025. The latest amendment is Regulation (EU) 2025/2650 of 19 December 2025. It was published in the Official Journal on 23 December 2025 and entered into force three days later.
| Who | Applies from |
|---|---|
| Large and medium operators | 30 December 2026 |
| Micro and small operators | 30 June 2027 |
| Micro and small operators already covered by the EU Timber Regulation | 30 December 2026 |
| Products added by Delegated Regulation (EU) 2026/2102 | 30 December 2027 |
The Commission’s EUDR Information System, where statements are filed, was launched on 4 December 2024. Companies can register and prepare before their date applies.
What does deforestation-free mean under the EUDR?
The German Federal Ministry of Labour and Social Affairs summarises Article 3 of the regulation as three conditions. A product may be placed on the market only if all three are met.
- Deforestation-free. It “must not originate from areas that were deforested after 31 December 2020.”
- Legal. Production complies with the laws of the country of production, in particular on land use, the environment and human rights.
- Covered by a due diligence statement. An electronic statement is available in the EU information system.
The cut-off date of 31 December 2020 is fixed. Land cleared after it cannot supply in-scope products for the EU market, whatever happens later on that land.
Who must submit a due diligence statement?
The operator. Regulation (EU) 2025/2650 concentrated the duty on the party that first places a relevant product on the EU market, or exports it. The European Parliament’s summary of the amendment describes it this way: first-placing operators bear the primary duty to submit due diligence statements. Downstream traders that only sell products already placed on the market no longer carry that burden.
The amendment also created a downstream operator category, with the same lighter obligations as traders. For small enterprises in low-risk countries, it introduced a one-time simplified declaration in place of repeated statements.
For imports, Finnish Customs sets out the practical point. Importers are required to draft a due diligence statement in the Commission’s EUDR system before importing goods covered by the regulation. Which entity is the operator in a given supply chain is a question to settle in writing before the first shipment.
What does due diligence involve?
The German ministry describes three stages.
- Information collection. Geolocation of every plot of production, to at least six decimal places, with polygons for plots over four hectares. Also the production period, product description and supplier details.
- Risk assessment. Supply chain complexity, forest presence, indigenous peoples in the area of origin, and the risk category of the country of production.
- Risk mitigation. Where the risk is not negligible: audits, supplier support, or not trading the goods if the risk cannot be reduced.
The geolocation requirement is where most importers meet difficulty. It has to come from the supply chain, often several steps upstream of the exporter.
How does the due diligence statement reach customs?
Through its reference number. When the statement is filed, the EUDR Information System issues a reference. Finnish Customs instructs importers to enter the reference number of the due diligence statement in the import declaration at release for free circulation. The entry uses condition code C716.
That makes the statement part of the customs file. Goods held in a customs warehouse and released later still need the reference at the moment of release. Release for free circulation explains what that release step involves.
A worked example
Suppose a furniture brand from outside the EU sells solid wood dining chairs and tables in Europe, from stock landed in Portugal. The details are hypothetical, for the mechanics only.
Its customs broker confirms that both products appear on the regulation’s product list. The brand’s EU importing company is a medium-sized enterprise, so its date is 30 December 2026.
The chairs use timber from one sawmill with its own forest concession. The tables use timber bought through two traders from several regions. From each supply chain, the importing company collects the geolocation of the forest plots and the harvest dates, then runs a risk assessment. The tables’ supply chain, with more intermediaries, needs more work than the chairs’.
Before each shipment is released, the importing company files the due diligence statement and receives its reference number. The customs declaration carries that number. Once released, the chairs and tables move to retailers, which as traders no longer file their own statements under the amended rules.
How EUDR applies to a particular product and supply chain is a question for the brand’s advisers. The example above shows the steps; it is not legal advice.
Where does EFC stand on EUDR?
EFC is not the EUDR operator for clients and does not file due diligence statements. Due diligence, supplier data and statements remain with the operator, which settles its role before goods ship. EFC’s part is the physical flow after release: storage, finishing and dispatch in its Portuguese warehouses, as described on warehousing and fulfilment. Brands weighing an EU importer structure can read importer of record without an EU entity.
Sources
| Label | Value | Source |
|---|---|---|
| Scope, dates, delegated act, information system | seven commodities; examples of derived products; 30 December 2026 and 30 June 2027; EUTR micro and small operators 30 December 2026; Delegated Regulation (EU) 2026/2102 from 30 December 2027; information system launched 4 December 2024 | European Commission, regulation on deforestation-free products, opened 2026-08-31 |
| Regulation (EU) 2025/2650 | of 19 December 2025; published 23 December 2025; in force three days later; operators file statements; downstream operators; simplified declaration | European Parliament, Legislative Train, targeted amendments to the EUDR, opened 2026-08-31 |
| Three conditions and due diligence | deforestation-free after 31 December 2020; legal production; statement in the information system; geolocation to six decimal places; polygons above four hectares | German Federal Ministry of Labour and Social Affairs, EUDR, opened 2026-08-31 |
| Customs declaration | importers draft the statement before import; reference number in the declaration at release for free circulation, condition code C716 (page published September 2025, before the December 2025 amendment) | Finnish Customs, EUDR and customs declarations, opened 2026-08-31 |