EUDR in plain terms
The EUDR - the EU Deforestation Regulation, formally Regulation (EU) 2023/1115 on deforestation-free products - bans the placing on the EU market, and the export from it, of seven commodities and their derived products unless the company can prove they did not come from land deforested after 31 December 2020. It is one of the most data-heavy compliance regimes the EU has introduced, because it requires companies to know exactly where the raw material was produced, down to the geographic coordinates of the plot of land.
If you make or sell furniture, lifestyle goods or packaging, this regulation almost certainly touches you. Wood is one of the seven covered commodities, and “derived products” reach far down the supply chain: furniture, wooden frames, paper and paperboard packaging, printed books, leather upholstery and footwear (from cattle), tyres and rubber components, and chocolate or coffee in any hospitality or gifting range. A brand that thinks of itself as a “furniture company” rather than a “timber importer” is still squarely in scope - and the obligations attach to the first company that places the finished or semi-finished product on the EU market.
Official text Read the regulation on EUR-Lex: Regulation (EU) 2023/1115 (CELEX 32023R1115).
Scope: seven commodities and their derived products
EUDR covers seven “relevant commodities”:
- Cattle
- Cocoa
- Coffee
- Oil palm
- Rubber
- Soya
- Wood
It then extends to a long list of derived products set out in the regulation’s annex - goods that contain, have been fed with, or have been made using those commodities. In practice that means furniture, leather goods, paper and paperboard, tyres, chocolate, palm-oil-based ingredients and many more. The decisive question is not what your company calls itself but whether the product appears on the annex list.
Operator vs trader
The regulation splits responsibility between two roles:
- An operator is the company that first places a relevant product on the EU market, or exports it. The operator carries the full due-diligence burden: collecting data, assessing risk and submitting the due-diligence statement before the product moves.
- A trader is anyone further down the chain who makes the product available on the market without being the first to place it. Large traders have due-diligence-style obligations close to those of operators; smaller traders mainly have to keep records of who supplied them and who they sold to, so the chain stays traceable.
For most furniture and lifestyle brands importing finished goods from outside the EU, you are the operator - the buck stops with you.
Key dates after the postponement
EUDR was adopted in 2023, but its application has been pushed back twice. The latest postponement came through amending Regulation (EU) 2025/2650 (December 2025), which reset the application dates as follows:
- Large operators and traders: obligations apply from 30 December 2026.
- Micro and small enterprises (SMEs): obligations apply from 30 June 2027.
The substance of the regulation did not change - only the start dates and some simplification measures. Do not read the delay as a reprieve: the geolocation and traceability data the regulation demands can take many months to gather from suppliers, so the work needs to start well before these dates.
Core requirements
EUDR is built around a due-diligence process that an operator must complete before a product is placed on the market or exported.
The due-diligence statement
Before a relevant product moves, the operator must submit an electronic due-diligence statement in the EU information system, confirming that due diligence was carried out and that the product is deforestation-free and legal. Filing this statement makes the operator legally responsible for its accuracy.
Geolocation data
The operator must collect the geolocation coordinates of all plots of land where the commodity was produced, together with the date or time range of production. For larger plots this means polygons rather than single points. This is the heart of EUDR and usually the hardest data to obtain, because it must come from the very start of the supply chain.
Risk assessment and mitigation
Using the geolocation data and country benchmarking (low, standard or high risk), the operator must assess the risk that the product is non-compliant. Where risk is more than negligible, the operator must take mitigation steps - additional information, surveys, audits or supplier engagement - until the risk is negligible. Only then may the product proceed.
The deforestation-free and legality test
A product passes only if it is both:
- Deforestation-free - produced on land not subject to deforestation or forest degradation after 31 December 2020; and
- Legal - produced in accordance with the relevant laws of the country of production (land use, environmental, labour, human rights, tax and trade rules).
Simplification for micro and small primary operators
The 2025 amendment introduced a lighter route for the smallest producers: a simplified, one-off due-diligence option is available for micro and small primary operators, reducing the repeated filing burden for those producing at the start of the chain. Larger operators and traders do not benefit from this simplification.
What to collect from suppliers now
Start building your data dossier before the deadlines arrive. For each relevant product line, ask suppliers for:
- The geolocation coordinates (points or polygons) of every plot of land of production, with production dates.
- The country of production (and region), so you can apply benchmarking.
- Evidence that production was legal under local law - permits, land titles, certifications.
- A clear chain of custody linking the plot to the batch you receive.
- Supporting documents such as harvest records, certificates (e.g. FSC/PEFC for wood) and supplier declarations - useful for risk mitigation, though certification alone does not replace due diligence.
Enforcement and penalties
Enforcement falls to competent authorities in each Member State, which carry out checks on operators and traders, prioritising high-risk countries and commodities. Authorities can demand the underlying data, inspect products and stop non-compliant goods from entering or leaving the market.
Penalties are set nationally but must be effective, proportionate and dissuasive. The regulation expects them to scale with the environmental and economic damage, and the toolkit includes fines (potentially a meaningful percentage of EU turnover), confiscation of products and revenues, exclusion from public procurement and temporary bans on placing products on the market. Reputational exposure is significant: non-compliance can become public and disrupt supply.
Getting compliant: a checklist
- Map your product range against the EUDR annex to confirm which lines are in scope.
- Determine your role - operator or trader - for each product.
- Identify which deadline applies: 30 December 2026 (large) or 30 June 2027 (SME).
- Set up supplier data collection for geolocation and legality evidence now.
- Build a risk assessment process using country benchmarking.
- Define mitigation steps for any more-than-negligible risk.
- Prepare to file due-diligence statements in the EU information system.
- Keep records for the retention period and assign clear internal ownership.
Related guides
- PPWR - Packaging and Packaging Waste Regulation
- WEEE - Waste Electrical and Electronic Equipment
- Batteries Regulation
How Conphora helps
Conphora automatically monitors EUDR and matches your products against the relevant requirements, including the post-2025 deadlines. The platform identifies gaps, helps you organise the geolocation and legality data you need from suppliers, and keeps you up to date when the rules change.
Sources
- EUR-Lex - Regulation (EU) 2023/1115 (CELEX 32023R1115)
- European Commission - Environment: deforestation-free products
This guide is for general information and is not legal advice.
Last updated: 12 June 2026