What Is the EU Deforestation Regulation?

The EUDR aims to ensure that certain commodities and products placed on the EU market or exported from the EU are not linked to deforestation, forest degradation, or illegal production.

In practical terms, covered products must meet three core conditions:

This means companies need to know where relevant commodities were produced, whether the production was legal, and whether there is any risk that the supply chain includes non-compliant or unknown-origin materials.

Which Products Are Covered by EUDR?

The EUDR applies only to relevant products listed in Annex I of the Regulation. These products are linked to seven key commodities:

• Cattle
• Cocoa
• Coffee
• Oil palm
• Rubber
• Soy
• Wood

A key clarification from the FAQ is that product scope depends on whether the product is listed in Annex I and whether it contains or is made from the relevant commodity listed in the corresponding category.

For example, a product may contain a commodity associated with EUDR, but if the product’s HS or CN code is not listed in Annex I, it may fall outside the scope. On the other hand, if a listed product is made from the relevant commodity, the EUDR obligations may apply regardless of quantity or value.

This makes product classification a critical first step in EUDR readiness.

Why Traceability Is at the Heart of EUDR Compliance

One of the most important messages in the April 2026 FAQ is that traceability must go back to the production area.

Operators placing covered products on the EU market or exporting them must collect geographic coordinates for the plots of land where the relevant commodities were produced. This geolocation data is needed to demonstrate that the product is not linked to deforestation or forest degradation.

For plots of land larger than four hectares, geolocation generally needs to be provided as polygons. For smaller plots, a single latitude and longitude point may be accepted. For cattle establishments, a single geolocation point may be sufficient.

The practical impact is significant. Companies must be able to connect products, suppliers, batches, and production locations in a structured and verifiable way.

Mass Balance Is Not Enough Under EUDR

The FAQ also clarifies that mass balance systems that mix deforestation-free commodities with commodities of unknown origin or non-deforestation-free commodities are not allowed under the EUDR.

This is a major operational point for companies dealing with bulk commodities such as soy, palm oil, coffee, cocoa, or rubber.

If compliant and non-compliant materials are mixed and the non-compliant part cannot be separated, the entire batch may be considered non-compliant. This means companies need stronger segregation, traceability, supplier data, and batch-level documentation.

For businesses, this creates a need to move from broad sustainability claims to evidence-based supply chain control.

Operators, Downstream Operators and Traders: Know Your Role

The FAQ explains that EUDR obligations depend heavily on the company’s role in the supply chain.

Importers and first sellers often carry the heaviest obligations because they are typically operators. However, downstream operators and traders still need to collect and keep information about their direct business partners and respond to substantiated concerns.

Non-SME downstream operators and non-SME traders also need to register in the EUDR Information System.

Due Diligence Is Not a Tick-Box Exercise

The Commission FAQ makes clear that due diligence under EUDR must be meaningful and risk based. Companies need to collect information, assess risk, and mitigate risk before placing relevant products on the EU market or exporting them.

A practical EUDR due diligence process should include:

1. Product scope assessment

Identify whether the product is listed in Annex I and linked to a relevant commodity.

2. Supplier and supply chain mapping

Identify suppliers, direct business partners, countries of production, and product flows.

3. Geolocation data collection

Collect plot-level or establishment-level production data where required.

4. Legality evidence collection

Gather reliable documentation showing compliance with relevant laws in the country of production.

5. Deforestation risk assessment

Review whether the production location is linked to deforestation or forest degradation after the cut-off date.

6. Risk mitigation

Request additional documents, improve supplier controls, use audits, or take corrective action where risk is not negligible.

7. DDS or SD preparation

Submit the correct declaration before placing the product on the EU market or exporting it.

8. Record keeping

Keep documentation for the required retention period and ensure it can be retrieved during audits or authority checks.

EUDR Timelines Businesses Need to Know

According to the April 2026 FAQ, the EUDR entered into force on 29 June 2023.

The substantive provisions apply from:

Products placed on the EU market before the relevant application date are generally treated differently from products placed after that date. However, companies should keep evidence to prove when products were produced or placed on the market, especially during the transition period.

For cattle, the FAQ clarifies that the relevant production date is linked to the date the animal was born.

1. What the EUDR Information System Means for Companies

   The EUDR Information System is the digital platform where operators submit Due Diligence Statements and Simplified Declarations.

   For import and export activities, businesses will need to ensure that the relevant declaration data is available before customs processes are completed. The system also supports geolocation data uploads, including GeoJSON files.

   This means EUDR compliance will require more than supplier engagement. Companies will need internal workflows that connect product classification, supplier evidence, geolocation files, declaration data, and customs requirements.

   Without a controlled digital process, companies may face delays, inconsistent documentation, or missing information at the point of import, export, or market placement.

1. Common EUDR Readiness Gaps

   Many companies are still underestimating the operational work required for EUDR compliance. Common gaps include:

   • No central list of products potentially in scope
   • Missing HS or CN code validation
   • Limited visibility beyond tier-one suppliers
   • Incomplete geolocation data
   • Supplier declarations stored in emails or spreadsheets
   • No process to assess deforestation risk
   • No clear ownership between procurement, compliance, sustainability, and logistics teams
   • Difficulty preparing DDS data in the correct format
   • Lack of audit-ready evidence

   The companies that prepare early will be in a stronger position to avoid supply disruption, customs delays, rejected declarations, and reputational risk.

EUDR Compliance Checklist for Businesses

Use this checklist to assess your readiness:

1. Why EUDR Preparation Should Start Now

   EUDR compliance affects sourcing, procurement, supplier onboarding, logistics, customs, sustainability reporting, and legal teams. Waiting until the application date creates unnecessary risk.

   Businesses should start by classifying products, identifying affected suppliers, collecting geolocation data, and building repeatable due diligence workflows.

   The strongest approach is to treat EUDR as a structured compliance management process, not a one-time supplier questionnaire.

   A good EUDR workflow should be:

   • Digital
   • Supplier-friendly
   • Evidence-based
   • Audit-ready
   • Connected to product and supply chain data
   • Flexible enough to reflect regulatory updates

1. How ComplyMarket Supports EUDR Compliance

   ComplyMarket helps companies transform EUDR requirements into a structured, digital, and scalable compliance workflow.

   With ComplyMarket, businesses can support EUDR readiness by managing supplier data, product scope, due diligence evidence, geolocation information, documentation, dashboards, and regulatory monitoring in one controlled process.

   ComplyMarket can support your teams with:

1. • Product and commodity scope assessment
     Identify products that may fall under EUDR based on commodity and product classification.
   • Supplier data collection
     Replace scattered emails with structured supplier questionnaires and evidence requests.
   • Geolocation and traceability workflows
     Collect and organize plot-level or establishment-level information required for EUDR due diligence.
   • Risk and evidence management
     Document legality evidence, deforestation-free checks, risk assessment, and mitigation steps.
   • DDS preparation support
     Organize the data needed for Due Diligence Statements and Simplified Declarations.
   • Audit-ready documentation
     Keep compliance records structured, searchable, and ready for authority or customer requests.
   • Continuous regulatory monitoring
     Stay aligned with EUDR updates and broader sustainability compliance obligations.

   For companies managing complex supply chains, EUDR compliance is not only about avoiding penalties. It is an opportunity to build stronger supply chain transparency, improve supplier accountability, and demonstrate a credible commitment to responsible sourcing.