EU Deforestation Regulation (EUDR) Explained: Which Products, What Proof, and What Deadlines

Which Commodities EUDR Covers#

EUDR Regulation 2023/1115 covers seven commodities and their derivatives: cattle (live animals and meat products, leather), cocoa (cocoa beans, cocoa paste, cocoa butter, chocolate), coffee (roasted and unroasted), palm oil (crude and refined, vegetable fats), soya (beans, meal, oil), wood (timber, charcoal, pulp, paper, furniture), and rubber (natural rubber, tyres, gloves). The regulation covers not just the raw commodity but an extensive list of derived products listed in Annex I — meaning a chocolate confectionery manufacturer is subject to EUDR, as is a furniture importer and a tyre company. The scope was deliberately drawn broadly to prevent manufacturers from reformulating products to avoid the regulation. Any product containing a covered commodity as an input is potentially in scope, regardless of the commodity's percentage of final product content.

The Core Legal Requirement: No Deforestation Link#

The fundamental EUDR requirement is that covered commodities and products must not have been produced on land that was deforested or degraded after 31 December 2020. 'Deforestation' is defined in the regulation as the conversion of forest to agricultural use — whether the conversion was legal under the country of origin's laws is irrelevant. Even legally cleared land counts as deforestation under EUDR if it was forested after the cut-off date. 'Forest degradation' covers the conversion of primary forests or naturally regenerating forests to other forest types. Operators must demonstrate that their commodities comply with this requirement through a due diligence system — not through a simple declaration, but through documented evidence.

Geolocation Data: The Technical Requirement#

EUDR requires operators to collect and provide the geolocation coordinates of every plot of land where the commodity was produced. For most agricultural commodities, this means polygon data (the boundary coordinates of each field or farm plot) rather than a single GPS point. This is a fundamentally different data requirement from most existing supply chain due diligence frameworks, which typically operate at country or regional level. For cocoa and coffee, this means tracing back to farm level across potentially thousands of smallholder farmers in origin countries. For palm oil, it means mapping every plantation block. The regulation does not prescribe the technical format for geolocation data, but the due diligence statement submitted to the EU information system must include the plot coordinates in a form that allows the Commission's systems to cross-reference against satellite deforestation monitoring.

The Due Diligence Statement and Reference Number#

Before placing covered commodities on the EU market or exporting them from the EU, operators must submit a due diligence statement through the EU EUDR Information System, which generates a reference number. This reference number must appear on customs documentation at import — without it, goods cannot be released into free circulation. The due diligence statement must include: operator details, commodity type and CN code, country of production, geolocation coordinates of production plots, quantity, a risk assessment conclusion (negligible risk), and descriptions of the risk mitigation measures applied. Customs authorities are required to check the reference number exists and may refer shipments for deeper documentary or physical checks. The due diligence information system was scheduled to be operational from mid-2024.

Compliance Deadlines and Country Risk Benchmarking#

EUDR compliance deadlines vary by operator size. Large operators and traders must comply from 30 December 2025 (originally June 2025 but delayed by 12 months in October 2023). Micro and small enterprises have until 30 June 2026. The Commission has also introduced a country benchmarking system that classifies countries as low, standard, or high risk for deforestation. Operators sourcing from low-risk countries have simplified due diligence obligations. Countries will be classified before the compliance deadline — no country has been formally classified yet as of early 2025. Critically, Brazil, Indonesia, and other high-volume origin countries for covered commodities are widely expected to receive standard or high-risk classifications, meaning full due diligence will be required for most major supply chains. AskBiz tracks EUDR country risk benchmarking decisions and compliance deadline updates.

• The EU Deforestation Regulation (EUDR) prohibits placing seven categories of commodities and their derivatives on the EU market if they are linked to deforestation after 31 December 2020.
• Operators must conduct supply chain due diligence, collect geolocation coordinates for every plot of land where the commodity was produced, and submit due diligence statements before importing.
• The compliance deadline is 30 December 2025 for large operators.