EUDR guide

What the EUDR is

The EUDR is Regulation (EU) 2023/1115 on deforestation-free products. Its core rule is simple: a product can only be placed on the EU market, or exported from it, if it meets three conditions at once:

1. It does not come from land deforested after 31 December 2020.
2. It was produced in line with the relevant legislation of the country of production.
3. It has a due diligence statement (DDS) submitted before it is placed on the market.

Source: Regulation (EU) 2023/1115, Articles 3 and 4(2), as amended by Regulation (EU) 2025/2650.

Why it exists

The regulation aims to minimize the EU's contribution to deforestation and forest degradation worldwide. It does not ask about the intent of the producer; it asks about the land. That is why the cut-off date is what gets verified, plot by plot.

Source: Regulation (EU) 2023/1115, Article 1(1)(a); Delegated Regulation (EU) 2026/2102.

The 7 commodities and their derivatives

The regulation covers seven commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood. But it does not cover only the raw commodity. It covers a list of products, Annex I, which includes derivatives. That list is identified by tariff code, not by name.

Some codes appear with "ex". That means only the part of the code that meets a condition is covered. For example, rubber counts only if it comes from Hevea brasiliensis, and oil palm derivatives only if they are made from oil palm.

Source: Annex I of Regulation (EU) 2023/1115, consolidated text as of 18 September 2026; Delegated Regulation (EU) 2026/2102.

Operator or trader: who is responsible to the EU

The regulation distinguishes four roles. Only the operator submits the DDS.

1. Operator. Whoever places a product on the EU market for the first time, or exports it from the EU. Usually the importer. If whoever places it is outside the EU, the first person who makes it available within the EU is considered the operator.

2. Downstream operator. Whoever uses products already covered by a DDS to manufacture another product and places it on the market. Does not submit a DDS.

3. Trader. Any other actor in the chain that makes the product available on the market. Does not submit a DDS either, but must keep the data of its suppliers and customers and the DDS reference numbers.

4. Authorized representative. Whoever submits the DDS on behalf of an operator established outside the EU, under a written mandate. Must be established in the EU.

Source: Regulation (EU) 2023/1115, Articles 4(2), 6 and 7; Regulation (EU) 2025/2650, Articles 2(15), 2(15b), 2(17) and 5.

When it applies, depending on operator size

Dates depend on the size of the operator in the EU. What counts is your buyer's size, not yours.

Source: Regulation (EU) 2023/1115, Article 38(2) and (3), as amended by Regulation (EU) 2025/2650. Definition of micro and small enterprise: Directive 2013/34/EU, Article 3.

How we arrived at these dates

The dates have moved twice. The sequence is:

1. Regulation (EU) 2023/1115, original. Published on 9 June 2023. Original dates: 30 December 2024 for large and medium-sized operators, and 30 June 2025 for micro and small.

2. Regulation (EU) 2024/3234. First one-year delay: 30 December 2025 and 30 June 2026.

3. Regulation (EU) 2025/2650. Second delay: 30 December 2026 and 30 June 2027. These are the dates in force.

4. European Commission, 4 May 2026 (COM(2026) 191). The Commission writes that it does not consider it appropriate to propose further changes to the basic text.

Source: Regulation (EU) 2023/1115, Article 38 (original); Regulation (EU) 2024/3234, Article 1; Regulation (EU) 2025/2650, Article 38; COM(2026) 191.

Delegated Regulation 2026/2102: changes to the product list

Delegated Regulation (EU) 2026/2102 has applied since 18 September 2026. It changes the product list. It does not change the dates for products that were already included.

• Out of scope from 18 September 2026: bovine leather (ex 4101, ex 4104 and ex 4107); rubber belts (ex 4010) and vulcanized rubber manufactures (ex 4016). Of heading 4012, only the tread bands (4012 90 30) remain.
• In scope from 30 December 2027: soluble coffee (2101 11 00), frozen bovine tongue and several oil palm derivatives.

Source: Delegated Regulation (EU) 2026/2102, Article 2 (enters into force the day after its publication in the Official Journal of 17 September 2026), recitals 5, 10 and 11, and annex.

Deforestation-free and the cut-off date

The first condition is that the product is deforestation-free. The cut-off date is 31 December 2020: the land cannot have been deforested after that day.

Three definitions help explain the rule:

• Deforestation. Conversion of forest to agricultural use, whether caused by humans or not.
• Forest. Land of more than 0.5 hectares, with trees taller than 5 meters and canopy cover above 10%. Land with predominantly agricultural or urban use does not count.
• Agricultural plantation. Land with trees within an agricultural production system, including agroforestry systems where crops grow under shade. It is not considered forest.

In a shade-grown coffee plot, what disqualifies it is not that it has trees. What disqualifies it is that the forest was converted to coffee after 31 December 2020. That is why you must be able to show that the plot was already a coffee plot before that date.

Source: Regulation (EU) 2023/1115, Articles 2(3), 2(4), 2(6), 2(13)(a) and 3(a), as amended by Regulation (EU) 2025/2650.

Production in line with the law of the country

The second condition is that the product was produced in line with the legislation of the country where it was produced. The regulation does not name any country's laws. It defines the subjects that this legislation must cover:

1. Land use rights.
2. Environmental protection.
3. Forest-related rules, where they relate to timber harvesting.
4. Third-party rights.
5. Labor rights.
6. Human rights recognized under international law.
7. Free, prior and informed consent of indigenous peoples.
8. Taxation, anti-corruption, trade and customs.

The evidence required is conclusive and verifiable information. It includes any agreement that gives the right to use the land: contract, permit or title.

The Commission and the International Trade Centre (ITC) are preparing a repository of legislation by country (LCR).

Source: Regulation (EU) 2023/1115, Articles 2(40), 3(b) and 9(1)(h). Commission Frequently Asked Questions (version 5, question 1.10), non-binding. Commission Green Forum page on EUDR implementation.

What gets delivered: the due diligence statement

The third condition is that a due diligence statement (DDS) is submitted before the product is placed on the European market. The DDS is the operator's electronic document. It contains:

1. Name, address and, where applicable, the operator's EORI number.
2. Tariff code, description and quantity in net kilograms.
3. Country of production and geolocation of all plots.
4. The declaration that due diligence was carried out and that no risk was found, or only negligible risk.
5. Signature.

By submitting it, the operator takes responsibility for the product complying with the regulation.

Source: Regulation (EU) 2023/1115, Articles 4(2), 4(3) and 9(1)(d), and Annex II, as amended by Regulation (EU) 2025/2650.

What geolocation is

Geolocation is the location of a plot using latitude and longitude coordinates, with at least six decimal places. It is the base data of the DDS: without it, you cannot verify that the land was not deforested.

A plot is a piece of land within a single property, recognized by the law of the country of production, with conditions that are homogeneous enough to assess deforestation risk. If the product comes from several plots, the geolocation of all of them must be included.

Source: Regulation (EU) 2023/1115, Articles 2(27), 2(28) and 9(1)(d).

Point or polygon: when each applies

There are two ways to declare location:

• Point. A coordinate with at least six decimal places. Sufficient for plots of up to 4 hectares.

• Polygon. A closed figure, with enough points to describe the perimeter of the plot. Mandatory for plots larger than 4 hectares.

The form is decided per plot, not per whole farm. If the plot is larger than 4 hectares, a single point is not enough.

Source: Regulation (EU) 2023/1115, Articles 2(28) and 34(2)(d). TRACES technical documentation, EUDR operator API reference v1.3, 17 August 2026.

The cattle exception

For cattle, a polygon is not required, even if the plot is larger than 4 hectares. Geolocation is provided with at least one point. In practice, the data they will ask you for is the location of the farm of origin.

Source: Regulation (EU) 2023/1115, Article 2(28) (cattle exception). Certification patterns in the bovine meat chain, from the October 2026 research.

The three steps of due diligence

Due diligence is the process of gathering information, assessing risk and reducing it before the product is placed on the EU market. It has three steps:

1. 1

   Gather information.

   The data and evidence under Article 9, per product.

2. 2

   Assess risk.

   The operator verifies the information and analyzes it against 14 criteria. These include the risk assigned to the country, the quality of the evidence, the difficulty of linking the product to its plot, and the risk of mixing with product of unknown origin.

3. 3

   Mitigate risk.

   If the risk is not zero or negligible, the operator requests additional information, carries out independent audits or takes other measures. It documents those decisions at least once a year.

Source: Regulation (EU) 2023/1115, Articles 8 to 12; Article 10(2)(a), (g), (i) and (j); Article 11(1); Article 12(2); recital (52) of the original text.

What information the regulation requires for each plot

Article 9 requires this information for each product, together with evidence:

1. Product description, with trade name and type.
2. Quantity, in net mass in kilograms.
3. Country of production.
4. Geolocation of all plots, with the date or period of production.
5. Name, address and email of each supplier.
6. Name, address and email of each downstream operator or trader the product was sold to.
7. Conclusive and verifiable information that the product is deforestation-free.
8. Information that it was produced in line with the country's legislation, including the right to use the land.

Source: Regulation (EU) 2023/1115, Article 9(1)(a) to (h), as amended by Regulation (EU) 2025/2650.

The DDS in the Commission's information system

The European Commission maintains a central information system where DDSs are registered. The operator can submit the DDS through a web form or an application programming interface.

On registration, the DDS receives a reference number. The operator communicates it to its buyers, and customs uses it when clearing the product. Supporting files do not travel with the DDS: the system receives structured data.

An operator outside the EU can only enter the system with a valid EORI number from a Member State.

Source: Regulation (EU) 2023/1115, Articles 4(2), 4(7), 33(1) and 33(2)(b). Commission FAQ, question 7.23.

Evidence: five years

The operator keeps for five years:

• The information and evidence under Article 9, counted from placing on the market or export.
• The record of DDSs submitted.
• The due diligence documentation and the record of its updates.

Source: Regulation (EU) 2023/1115, Articles 4(3), 9(1), 12(2) and 12(5), as amended by Regulation (EU) 2025/2650.

What the risk classification is

The Commission assigns each country, or parts of a country, a risk level: low, standard or high. Countries at low and high risk are on a list in an implementing regulation. All others are standard risk.

The level changes what is required:

Source: Regulation (EU) 2023/1115, Articles 13(1) and 29(2); Regulation (EU) 2025/2650, Articles 2(15a) and 16(8) to (10); Implementing Regulation (EU) 2025/1093, Article 1(1) and (2).

Mexico: standard risk and what it means

Mexico does not appear on the low-risk list or the high-risk list. That is why it has standard risk. The high-risk list includes only Belarus, North Korea, Myanmar and Russia.

In practice, this means:

• The importer cannot skip the risk assessment or risk mitigation.
• There is no simplified procedure for Mexican producers. The importer needs the location of each plot.
• Each year, EU authorities check at least 3% of operators that bring in products from standard-risk countries, and of the other actors in the chain that are not SMEs.

Source: Implementing Regulation (EU) 2025/1093, Article 1(1) and (2); Regulation (EU) 2023/1115, Articles 10(2)(a) and 13(1); Regulation (EU) 2025/2650, Article 16(8).

How each commodity travels

The typical chain has these links: the producer, the collection point or cooperative, processing in Mexico (milling, grinding or factory), the exporter, the importer in the EU (operator) and, after that, the European processor or distributor.

Not every commodity starts in Mexico. This table shows the origin of each commodity and the value the EU recorded as imported from Mexico in 2025:

Source: UN Comtrade, EU imports from Mexico, 2025; Annex I of Regulation (EU) 2023/1115. Origin of the commodity: Mexican coffee production from 2021 and Mexico's foreign trade from 2024.

Who carries each piece of data

Each link has data it must gather. If one fails, the importer's DDS cannot be submitted.

1. Producer. Coordinates or polygon for each plot, date or period of production, and the agreement giving the right to use the land.

2. Cooperative or aggregator. Consolidates its members' data and links each plot to the lot it delivers.

3. Processor in Mexico. Connects each output lot with the input lots and with their plots.

4. Exporter. Gives the importer the suppliers, plots, lots and legality evidence.

5. Importer in the EU (operator). Submits the DDS Submits the DDS, carries out the risk assessment and keeps the evidence for five years.

6. Processor or distributor in the EU. Receives the DDS reference number and keeps the data of its chain.

Source: Regulation (EU) 2023/1115, Articles 4(7), 5(3), 9(1), 10(2)(i) and 12(5). Commission FAQ, question 3.20, on cooperatives as representatives.

Where the chain breaks: mixing and segregation

The most fragile point in the chain is mixing. If a lot combines product from a known plot with product of unknown origin, the lot cannot be verified. The regulation requires assessing the risk of that mixing.

Practical rules:

1. Each lot must be able to state which plots it comes from.
2. Certifications help, but they do not replace the plot-level data the DDS requires: the geolocation of each plot and the link to each lot.

Source: Regulation (EU) 2023/1115, Article 10(2)(j).

Three steps to start

1. 1

   Check your product.

   Look up the tariff code of what you export in the Annex I list. If the code does not appear, the regulation does not apply to that product.

2. 2

   Ask your buyer.

   What size it is as an operator in the EU and from which date it will ask you for data. That date is the one that counts for your calendar.

3. 3

   Take the self-assessment.

   It takes 15 to 20 minutes as an individual producer, or 25 to 35 as a cooperative or organization. It tells you where you stand today and what you are missing.

Source: Regulation (EU) 2023/1115, Articles 4(2) and 38, and Annex I.

What to have ready before the call

If you arrive at the call with this, the review of your case moves faster:

1. The commodities and codes of each product you export.
2. The size and country of your buyer, and its application date.
3. The list of suppliers or producers, with how many plots each has and how many already have a location.
4. For plots up to 4 hectares, one coordinate. For those over 4 hectares, a polygon.
5. The agreement giving the right to use each plot: contract, permit or title.
6. The link between each lot you export and the plots it comes from.
7. The date or period of production of each lot.

Source: Regulation (EU) 2023/1115, Articles 2(28), 4(2) and 9(1)(d) to (h).