{ "$schema": "https://www.conphora.com/schemas/regulation-page.json", "code": "EUDR", "locale": "en", "url": "https://www.conphora.com/regulations/eudr/", "json": "https://www.conphora.com/regulations/eudr.json", "summaryPdf": "https://www.conphora.com/regulations/eudr/summary.pdf", "dateModified": "2026-09-09", "regulation": { "code": "EUDR", "name": "Regulation (EU) 2023/1115 of the European Parliament and of the Council of 31 May 2023 on the making available on the Union market and the export from the Union of certain commodities and products associated with deforestation and forest degradation and repealing Regulation (EU) No 995/2010", "shortName": "EU Deforestation Regulation", "reference": "Regulation (EU) 2023/1115", "celex": "32023R1115", "eurlex": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1115", "actType": "Regulation", "category": "Environment & Waste", "inForce": "2023-06-29", "appliesFrom": "2026-12-30", "changing": true, "video": "regulation-eudr" }, "answer": "The EU Deforestation Regulation bans placing on the EU market or exporting cattle, cocoa, coffee, oil palm, rubber, soya, wood and their Annex I products unless they are deforestation-free, legally produced and covered by a due diligence statement. After two postponements its obligations apply from 30 December 2026, or from 30 June 2027 for micro and small operators.", "description": "EUDR guide: the EU Deforestation Regulation, who it applies to, key dates after the 2024 and 2025 postponements, and how to ensure compliance.", "enforcedBy": "Competent authorities designated by each Member State enforce the regulation with penalties that must include fines whose maximum for legal persons must be at least 4 % of total annual EU-wide turnover, confiscation of the products and of the revenues from them, exclusion from public procurement and public funding for up to 12 months, and temporary bans on placing products on the market or exporting them.", "keyDates": [ { "date": "2020-12-31", "label": "Cut-off date: commodities must come from land not subject to deforestation after this date, and wood must be harvested without forest degradation after it", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 2(13)" }, { "date": "2023-06-09", "label": "Regulation (EU) 2023/1115 published in the Official Journal (OJ L 150, p. 206)", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1115" }, { "date": "2023-06-29", "label": "Entry into force (twentieth day after publication); all countries assigned a standard level of risk", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 38(1) and Art. 29(2)" }, { "date": "2024-12-04", "label": "The EU information system for due diligence statements (Article 33) is launched by the Commission", "source": "https://environment.ec.europa.eu/topics/forests/deforestation/regulation-deforestation-free-products_en" }, { "date": "2024-12-26", "label": "Regulation (EU) 2024/3234 enters into force: first postponement of the application dates by 12 months (to 30 December 2025 and 30 June 2026)", "source": "https://eur-lex.europa.eu/eli/reg/2024/3234/oj · Art. 1 and Art. 2" }, { "date": "2025-06-30", "label": "Deadline for the Commission to publish, by implementing act, the list of low-risk and high-risk countries", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 29(2)" }, { "date": "2025-12-26", "label": "Regulation (EU) 2025/2650 enters into force: second 12-month postponement, new downstream operator role and simplified regime for micro or small primary operators", "source": "https://eur-lex.europa.eu/eli/reg/2025/2650/oj · Art. 1 and Art. 2" }, { "date": "2026-04-30", "label": "Deadline for the Commission's simplification review and report, with a legislative proposal where appropriate", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 34(1a)" }, { "date": "2026-12-30", "label": "Articles 3 to 13, 16 to 24, 26, 31 and 32 apply to operators, downstream operators and traders; Regulation (EU) No 995/2010 (EU Timber Regulation) is repealed", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 38(2) and Art. 37(1)" }, { "date": "2027-06-30", "label": "Application for operators that are natural persons or micro or small undertakings established by 31 December 2024, except for products covered by the annex to the EU Timber Regulation", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 38(3)" }, { "date": "2029-12-31", "label": "End of the transition under which the EU Timber Regulation still applies to timber produced before 29 June 2023 and placed on the market from 30 December 2026", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 37(2)" }, { "date": "2030-06-30", "label": "First general review of the regulation by the Commission, then at least every five years", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 34(2)" } ], "amendedBy": [ { "reference": "Regulation (EU) 2024/3234", "celex": "32024R3234", "date": "2024-12-19", "summary": "Postponed the date of application by 12 months, to 30 December 2025 for operators and traders and 30 June 2026 for micro and small undertakings; replaced Article 37 so that the repeal of Regulation (EU) No 995/2010 (EU Timber Regulation) moved to 30 December 2025, with that regulation continuing to apply until 31 December 2028 to timber produced before 29 June 2023 and placed on the market from 30 December 2025; and moved the deadline for the country risk classification to 30 June 2025. Published 23 December 2024, in force on the third day after publication.", "source": "https://eur-lex.europa.eu/eli/reg/2024/3234/oj · Art. 1 and Art. 2" }, { "reference": "Regulation (EU) 2025/2650", "celex": "32025R2650", "date": "2025-12-19", "summary": "Postponed application by a further 12 months, to 30 December 2026 and 30 June 2027, and moved the repeal of the EU Timber Regulation to 30 December 2026; amended the definitions in Article 2 (operator now excludes downstream operators, trader redefined, new definitions of micro or small primary operator and downstream operator, and revised definitions of commercial activity, authorised representative and SMEs); introduced the downstream operator role with information duties instead of full due diligence, a one-time simplified declaration for micro or small primary operators in low-risk countries (new Article 4a and Annex III), registration of non-SME downstream operators and traders in the information system, and a simplification review by 30 April 2026; deleted from Annex I the line for chapter 49 (printed books, newspapers, pictures and other products of the printing industry, manuscripts, typescripts and plans, of paper) and point 4 of Annex II. Published 23 December 2025, in force on the third day after publication.", "source": "https://eur-lex.europa.eu/eli/reg/2025/2650/oj · Art. 1 and Art. 2" } ], "scope": { "appliesTo": [ "Cattle", "Cocoa", "Coffee", "Oil palm", "Rubber", "Soya", "Wood" ], "derived": [ "Live cattle, beef and edible offal of cattle", "Raw and tanned hides and skins of cattle, and cattle leather", "Cocoa beans, paste, butter and powder, and chocolate and other food preparations containing cocoa", "Coffee, roasted or not, and coffee substitutes containing coffee", "Palm nuts and kernels, palm oil and palm kernel oil, glycerol, palmitic and stearic acid, industrial fatty acids and fatty alcohols", "Natural rubber, compounded and vulcanised rubber, tyres, inner tubes, conveyor belts and other articles of rubber", "Soya beans, soya bean flour and meal, soya-bean oil and oilcake", "Fuel wood, charcoal, wood in the rough, sawn wood and veneer sheets", "Plywood, particle board, OSB, fibreboard and densified wood", "Wooden packing cases, crates, pallets and casks, except packing material used exclusively to support, protect or carry another product", "Builders' joinery, wooden tools and handles, tableware and kitchenware, frames and other articles of wood", "Pulp, paper and paperboard of chapters 47 and 48, except bamboo-based and recovered (waste and scrap) products", "Wooden seats, wooden furniture and parts thereof, and prefabricated buildings of wood" ], "categories": [ { "id": "cattle", "label": "Cattle: live animals, beef, offal, hides and leather" }, { "id": "cocoa", "label": "Cocoa: beans, paste, butter, powder and chocolate" }, { "id": "coffee", "label": "Coffee, roasted or not" }, { "id": "oil-palm", "label": "Oil palm: palm oil, palm kernel oil, glycerol and fatty acids" }, { "id": "rubber", "label": "Rubber: natural rubber, tyres, tubes and rubber articles" }, { "id": "soya", "label": "Soya: beans, flour, oil and oilcake" }, { "id": "wood", "label": "Wood: timber, panels, packaging, joinery and furniture" }, { "id": "pulp-paper", "label": "Pulp, paper and paperboard" }, { "id": "other", "label": "Another product not listed in Annex I" } ], "roles": [ { "id": "operator", "label": "Operator", "definition": "Any natural or legal person who, in the course of a commercial activity, places relevant products on the market (the first making available on the Union market) or exports them, excluding downstream operators.", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 2(15) and Art. 2(16)" }, { "id": "importer", "label": "Importer (first company established in the EU)", "definition": "Where a person established outside the Union places relevant products on the market, the first natural or legal person established in the Union who makes them available on the market is deemed to be the operator.", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 7" }, { "id": "manufacturer", "label": "Downstream operator", "definition": "Any natural or legal person who, in the course of a commercial activity, places on the market or exports relevant products made using relevant products, all of which are already covered by a due diligence statement or a simplified declaration.", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 2(15b)" }, { "id": "trader", "label": "Trader", "definition": "Any person in the supply chain other than the operator or downstream operator who, in the course of a commercial activity, makes relevant products available on the market.", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 2(17)" }, { "id": "producer", "label": "Micro or small primary operator", "definition": "An operator who is a natural person or a micro or small undertaking within the meaning of Article 3(1) and Article 3(2), first subparagraph, of Directive 2013/34/EU, irrespective of its legal form, established in a country classified as low risk in accordance with Article 29, and who, in the course of a commercial activity, places on the market or exports relevant products that this operator itself has grown, harvested, obtained from or raised on relevant plots of land or, as regards cattle, on establishments located in that country. This includes operators that exceed the limits of at least two of the three size criteria of the Directive but can demonstrate that the parts of their balance sheet total, net turnover and average number of employees during the financial year related to the relevant commodities and relevant products do not exceed the limits of at least two of those three criteria.", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 2(15a)" } ], "rules": [ { "categories": [ "other" ], "roles": [ "*" ], "size": "any", "result": "out-of-scope", "note": "The regulation applies only to the products listed in Annex I that contain, have been fed with or have been made using cattle, cocoa, coffee, oil palm, rubber, soya or wood. Check the annex line for your CN code before concluding; goods made entirely from material that has completed its life cycle as waste are also excluded.", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 1(1) and Annex I" }, { "categories": [ "*" ], "roles": [ "producer" ], "size": "large", "result": "depends", "note": "A producer that exceeds the limits of at least two of the three size criteria for micro and small undertakings in Article 3(1) and (2) of Directive 2013/34/EU is still a micro or small primary operator if it is established in a country classified as low risk, itself grew, harvested, obtained or raised the commodities on plots of land or cattle establishments in that country, and can demonstrate that the parts of its balance sheet total, net turnover and average number of employees related to the relevant commodities and products do not exceed the limits of at least two of those criteria. Otherwise it is an operator with full due diligence and a due diligence statement per product.", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 2(15a), Art. 4 and Art. 4a" }, { "categories": [ "*" ], "roles": [ "producer" ], "size": "sme", "result": "depends", "note": "A micro or small undertaking within the meaning of Article 3(1) and (2) of Directive 2013/34/EU, established in a country classified as low risk, that itself grew, harvested, obtained or raised the commodities on plots of land or cattle establishments in that country is a micro or small primary operator and files a one-time simplified declaration instead of due diligence statements. A medium-sized undertaking qualifies only if it can demonstrate that the parts of its balance sheet total, net turnover and average number of employees related to the relevant commodities and products do not exceed the limits of at least two of the three micro or small criteria. A producer established in a standard-risk or high-risk country is an operator with full due diligence.", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 2(15a) and Art. 4a" }, { "categories": [ "*" ], "roles": [ "producer" ], "size": "micro", "result": "depends", "note": "An operator that is a natural person or a micro undertaking within the meaning of Article 3(1) of Directive 2013/34/EU, established in a country classified as low risk, that itself grew, harvested, obtained or raised the commodities on plots of land or cattle establishments located in that country is a micro or small primary operator: it submits a one-time simplified declaration with the Annex III information and may give postal addresses instead of geolocation. Established in a standard-risk or high-risk country, it is an operator with full due diligence.", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 2(15a) and Art. 4a" }, { "categories": [ "*" ], "roles": [ "operator", "importer" ], "size": "large", "result": "in-scope", "note": "Full due diligence before each placing on the market or export, a due diligence statement in the EU information system, and as a non-SME an annual public report, a compliance officer at management level and an independent audit function. Applies from 30 December 2026.", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 4, Art. 8 to 12 and Art. 38(2)" }, { "categories": [ "wood", "pulp-paper" ], "roles": [ "operator", "importer" ], "size": "sme", "result": "in-scope", "note": "Full due diligence and a due diligence statement per product. The later date of 30 June 2027 does not apply to products covered by the annex to Regulation (EU) No 995/2010 (EU Timber Regulation), which lists fuel wood, wood in the rough, railway sleepers, sawn wood, veneer sheets, continuously shaped wood, particle board, OSB, fibreboard, plywood, densified wood, wooden frames, packing cases, pallets and casks, builders' joinery, pulp and paper of chapters 47 and 48, wooden furniture of heading 9403 and prefabricated wooden buildings; for those products the obligations apply from 30 December 2026 regardless of size. Check whether your CN code is in that annex.", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 4, Art. 8 to 12 and Art. 38(3); https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32010R0995 · Annex" }, { "categories": [ "wood", "pulp-paper" ], "roles": [ "operator", "importer" ], "size": "micro", "result": "in-scope", "note": "Full due diligence and a due diligence statement per product. The later date of 30 June 2027 does not apply to products covered by the annex to Regulation (EU) No 995/2010 (EU Timber Regulation), which lists fuel wood, wood in the rough, railway sleepers, sawn wood, veneer sheets, continuously shaped wood, particle board, OSB, fibreboard, plywood, densified wood, wooden frames, packing cases, pallets and casks, builders' joinery, pulp and paper of chapters 47 and 48, wooden furniture of heading 9403 and prefabricated wooden buildings; for those products the obligations apply from 30 December 2026 regardless of size. Check whether your CN code is in that annex.", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 4, Art. 8 to 12 and Art. 38(3); https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32010R0995 · Annex" }, { "categories": [ "*" ], "roles": [ "operator", "importer" ], "size": "sme", "result": "in-scope", "note": "Full due diligence and a due diligence statement per product. Obligations apply from 30 December 2026. For operators that are small undertakings within the meaning of Article 3(2), first subparagraph, of Directive 2013/34/EU, irrespective of their legal form, that were established as such by 31 December 2024, they apply from 30 June 2027, except for products covered by the annex to the EU Timber Regulation; a medium-sized undertaking does not benefit from the later date.", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 4, Art. 8 to 12 and Art. 38(3)" }, { "categories": [ "*" ], "roles": [ "operator", "importer" ], "size": "micro", "result": "in-scope", "note": "Full due diligence and a due diligence statement per product. For operators that are natural persons or micro undertakings within the meaning of Article 3(1) of Directive 2013/34/EU, irrespective of their legal form, that were established as such by 31 December 2024, the obligations apply from 30 June 2027, except for products covered by the annex to the EU Timber Regulation; otherwise they apply from 30 December 2026.", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 4, Art. 8 to 12 and Art. 38(3)" }, { "categories": [ "*" ], "roles": [ "manufacturer", "trader" ], "size": "large", "result": "in-scope", "note": "Non-SME downstream operators and traders register in the EU information system, keep supplier and customer details with the due diligence statement reference numbers for at least five years, verify due diligence when a substantiated concern arises and inform the authorities before placing a product they know to be non-compliant. Applies from 30 December 2026. You are a downstream operator only if the relevant products you use are all covered by a due diligence statement or a simplified declaration; a person who places on the market or exports relevant products that are not all covered is an operator, and a trader is any other person in the supply chain who makes relevant products available on the market. Downstream operators and traders may place or make available on the market or export relevant products only if they possess the Article 5(3) information.", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 2(15), 2(15b) and 2(17), Art. 5 and Art. 38(2)" }, { "categories": [ "*" ], "roles": [ "manufacturer", "trader" ], "size": "sme", "result": "in-scope", "note": "SME downstream operators and traders keep the names, addresses and email addresses of their suppliers and customers, with the due diligence statement reference numbers or declaration identifiers where the supplier is an operator, for at least five years, and inform the authorities immediately of new risk information. Applies from 30 December 2026. You are a downstream operator only if the relevant products you use are all covered by a due diligence statement or a simplified declaration; a person who places on the market or exports relevant products that are not all covered is an operator, and a trader is any other person in the supply chain who makes relevant products available on the market. Downstream operators and traders may place or make available on the market or export relevant products only if they possess the Article 5(3) information.", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 2(15), 2(15b) and 2(17), Art. 5 and Art. 38(2)" }, { "categories": [ "*" ], "roles": [ "manufacturer", "trader" ], "size": "micro", "result": "in-scope", "note": "Micro downstream operators and traders keep the names, addresses and email addresses of their suppliers and customers, with the due diligence statement reference numbers or declaration identifiers where the supplier is an operator, for at least five years, and inform the authorities immediately of new risk information. Applies from 30 December 2026. You are a downstream operator only if the relevant products you use are all covered by a due diligence statement or a simplified declaration; a person who places on the market or exports relevant products that are not all covered is an operator, and a trader is any other person in the supply chain who makes relevant products available on the market. Downstream operators and traders may place or make available on the market or export relevant products only if they possess the Article 5(3) information.", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 2(15), 2(15b) and 2(17), Art. 5 and Art. 38(2)" }, { "categories": [ "*" ], "roles": [ "*" ], "size": "any", "result": "depends", "note": "The product is a relevant product. Establish whether you are the first to place it on the Union market or to export it (operator), whether every relevant product you use is already covered by a due diligence statement or a simplified declaration (downstream operator), or whether you only make it available further down the chain (trader).", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 2(15), Art. 2(15b) and Art. 2(17)" } ] }, "obligations": { "operator": [ { "text": "Exercise due diligence for all relevant products before placing them on the market or exporting them: collect the information required by Article 9, assess the risk under Article 10 and mitigate it under Article 11.", "id": "eudr-op-exercise-due-diligence", "kind": "procedure", "level": "lot", "timing": "per-lot", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 4(1) and Art. 8" }, { "text": "Do not place a relevant product on the market or export it without first making a due diligence statement available to the competent authorities through the EU information system, containing the Annex II information and a declaration that due diligence was exercised and no or only a negligible risk was found.", "id": "eudr-op-place-relevant-product", "kind": "submission", "level": "lot", "timing": "per-lot", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 4(2) and Annex II" }, { "text": "By making the statement available you assume responsibility for the product's compliance with Article 3; keep a record of each due diligence statement for five years from submission.", "id": "eudr-op-making-statement-available", "kind": "standing", "level": "company", "timing": "ongoing", "sharedKey": "record-keeping-5y", "retired": "2026-09-24", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 4(3)" }, { "text": "By making the due diligence statement available to the competent authorities you assume responsibility for the product's compliance with Article 3.", "id": "eudr-op-assume-responsibility-statement", "kind": "status", "level": "product", "timing": "before-market", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 4(3)" }, { "text": "Keep a record of each due diligence statement for five years from its submission.", "id": "eudr-op-keep-statements-five-years", "kind": "standing", "level": "company", "timing": "ongoing", "sharedKey": "record-keeping-5y", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 4(3)" }, { "text": "Collect, organise and keep for five years, with evidence: a product description including the common and scientific species names for wood, the quantity, the country of production, the geolocation of all plots of land (or cattle establishments) with the date or time range of production, the names, postal and email addresses of suppliers and customers, and adequately conclusive and verifiable information that the product is deforestation-free and was produced legally.", "id": "eudr-op-collect-organise-keep", "kind": "data", "level": "lot", "timing": "per-lot", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 9(1)" }, { "text": "Provide geolocation as latitude and longitude with at least six decimal digits; plots of more than four hectares used for commodities other than cattle must be described by polygons. Any deforestation or forest degradation on a plot disqualifies all commodities and products from it.", "id": "eudr-op-provide-geolocation-latitude", "kind": "data", "level": "lot", "timing": "per-lot", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 2(28) and Art. 9(1)(d)" }, { "text": "Carry out a risk assessment against the Article 10(2) criteria, including the country's risk classification, the presence of forests and indigenous peoples, supply chain complexity and the risk of circumvention; place the product only where the assessment reveals no or only a negligible risk; document and review the assessment at least annually.", "id": "eudr-op-carry-out-risk", "kind": "procedure", "level": "product", "timing": "before-market", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 10" }, { "text": "Where the risk is not negligible, adopt mitigation measures before placing the product, such as requiring additional information, independent surveys or audits; keep adequate policies, controls and procedures, and as a non-SME operator appoint a compliance officer at management level and an independent audit function; document mitigation decisions and review them at least annually.", "id": "eudr-op-adopt-mitigation-measures", "kind": "decision", "level": "product", "timing": "before-market", "retired": "2026-09-24", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 11" }, { "text": "Where the risk assessment reveals a non-negligible risk, adopt mitigation measures before placing the product, such as requiring additional information, independent surveys or audits, and document the mitigation decisions and review them at least annually.", "id": "eudr-op-adopt-risk-mitigation", "kind": "decision", "level": "product", "timing": "before-market", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 11(1) and Art. 11(3)" }, { "text": "Keep adequate and proportionate policies, controls and procedures to mitigate and manage the risk of non-compliance, and as a non-SME operator appoint a compliance officer at management level and an independent audit function.", "id": "eudr-op-keep-mitigation-policies", "kind": "standing", "level": "company", "timing": "ongoing", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 11(2)" }, { "text": "Establish and keep up to date a due diligence system, review it at least once a year, keep a record of updates and all due diligence documentation for at least five years, and make it available to the competent authorities on request.", "id": "eudr-op-establish-keep-date", "kind": "standing", "level": "company", "timing": "ongoing", "retired": "2026-09-24", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 12(1), 12(2) and 12(5)" }, { "text": "Establish and keep up to date a due diligence system, and review it at least once a year.", "id": "eudr-op-keep-due-diligence-system", "kind": "standing", "level": "company", "timing": "periodic", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 12(1) and Art. 12(2)" }, { "text": "Keep a record of the updates to the due diligence system and all documentation related to due diligence for at least five years, and make it available to the competent authorities on request.", "id": "eudr-op-keep-due-diligence-records", "kind": "standing", "level": "company", "timing": "ongoing", "sharedKey": "record-keeping-5y", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 12(2) and Art. 12(5)" }, { "text": "As an operator that is not an SME or a natural person, report publicly every year, including on the internet, on the due diligence system and the steps taken to fulfil the due diligence obligations, including a summary of products and countries, the conclusions of the risk assessment and the mitigation measures.", "id": "eudr-op-operator-sme-natural", "kind": "evidence", "level": "company", "timing": "periodic", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 12(3) and 12(4)" }, { "text": "Where all relevant commodities and products come from countries classified as low risk, you may use simplified due diligence and skip the risk assessment and mitigation steps, after assessing supply chain complexity and the risk of circumvention or mixing; keep documentation showing that risk is negligible and fall back to full due diligence as soon as any risk information arises.", "id": "eudr-op-use-simplified-due", "kind": "decision", "level": "product", "timing": "before-market", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 13" }, { "text": "Immediately inform the competent authorities and the downstream operators and traders you supplied when new information, including substantiated concerns, indicates that a product you placed on the market is at risk of non-compliance; give the authorities all necessary assistance for checks, including access to premises, documents and records.", "id": "eudr-op-immediately-inform-competent", "kind": "submission", "level": "product", "timing": "on-event", "retired": "2026-09-24", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 4(5) and 4(6)" }, { "text": "Immediately inform the competent authorities and the downstream operators and traders you supplied when new information, including substantiated concerns, indicates that a product you placed on the market is at risk of non-compliance.", "id": "eudr-op-inform-risk-non-compliance", "kind": "submission", "level": "product", "timing": "on-event", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 4(5)" }, { "text": "Offer all necessary assistance to the competent authorities for checks, including access to premises, documentation and records.", "id": "eudr-op-offer-necessary-assistance", "kind": "standing", "level": "company", "timing": "ongoing", "sharedKey": "authority-cooperation", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 4(6)" }, { "text": "Communicate the reference numbers of your due diligence statements, or the declaration identifiers, to the downstream operators and traders further down the supply chain.", "id": "eudr-op-communicate-reference-numbers", "kind": "data", "level": "lot", "timing": "per-lot", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 4(7)" }, { "text": "You may mandate an authorised representative established in the Union to submit the statement on your behalf, but you retain responsibility for the product's compliance.", "id": "eudr-op-mandate-authorised-representative", "kind": "decision", "level": "company", "timing": "before-market", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 6(1)" } ], "importer": [ { "text": "When a person established outside the Union places relevant products on the market, the first natural or legal person established in the Union who makes them available is deemed the operator and carries every operator obligation, including due diligence and the due diligence statement.", "id": "eudr-imp-first-natural-legal", "kind": "status", "level": "company", "timing": "before-market", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 7 and Art. 4" }, { "text": "For products released for free circulation or exported, include your EORI number in the information system registration and in the due diligence statement; the products are subject to the customs controls of Chapter 4.", "id": "eudr-imp-include-eori-number", "kind": "submission", "level": "lot", "timing": "per-lot", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 33(2)(a), Annex II(1) and Art. 26" } ], "manufacturer": [ { "text": "Place on the market, make available or export relevant products only when you hold the Article 5(3) information; your downstream operator status depends on every relevant product you use being covered by a due diligence statement or simplified declaration, otherwise you are an operator.", "id": "eudr-mfr-place-market-make", "kind": "verification", "level": "product", "timing": "before-market", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 5(1) and Art. 2(15b)" }, { "text": "As a non-SME downstream operator, register in the EU information system before placing, making available or exporting relevant products.", "id": "eudr-mfr-non-sme-downstream-operator", "kind": "submission", "level": "company", "timing": "before-market", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 5(2)" }, { "text": "Collect and keep the name, registered trade name or trade mark, postal address, email address and, if available, web address of your suppliers and, where the supplier is an operator, the reference numbers of the due diligence statements or the declaration identifiers, plus the same details of the downstream operators or traders you supply.", "id": "eudr-mfr-collect-keep-name", "kind": "data", "level": "lot", "timing": "per-lot", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 5(3)" }, { "text": "Keep that information for at least five years from placing, making available or export and provide it to the competent authorities on request.", "id": "eudr-mfr-keep-information-least", "kind": "standing", "level": "company", "timing": "ongoing", "sharedKey": "record-keeping-5y", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 5(4)" }, { "text": "Immediately inform the competent authorities and the parties you supplied when new information indicates that a product you placed or made available is at risk of non-compliance; as a non-SME, inform the authorities before placing a product you know to be non-compliant, verify that due diligence was exercised when there is a substantiated concern, and do not place the product unless the verification shows no or only a negligible risk.", "id": "eudr-mfr-immediately-inform-competent", "kind": "submission", "level": "product", "timing": "on-event", "retired": "2026-09-24", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 5(5) and 5(6)" }, { "text": "Immediately inform the competent authorities and the parties you supplied when new information indicates that a product you placed or made available is at risk of non-compliance.", "id": "eudr-mfr-inform-risk-non-compliance", "kind": "submission", "level": "product", "timing": "on-event", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 5(5)" }, { "text": "As a non-SME, inform the authorities before placing a product you know to be non-compliant, verify that due diligence was exercised when there is a substantiated concern, and do not place the product unless the verification shows no or only a negligible risk.", "id": "eudr-mfr-verify-substantiated-concerns", "kind": "verification", "level": "product", "timing": "on-event", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 5(6)" }, { "text": "Offer all necessary assistance to the competent authorities for checks, including access to premises, documentation and records.", "id": "eudr-mfr-offer-necessary-assistance", "kind": "standing", "level": "company", "timing": "ongoing", "sharedKey": "authority-cooperation", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 5(7)" } ], "trader": [ { "text": "Make relevant products available on the market only when you hold the Article 5(3) supplier and customer information.", "id": "eudr-trd-make-relevant-products", "kind": "verification", "level": "product", "timing": "before-market", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 5(1)" }, { "text": "As a non-SME trader, register in the EU information system before placing, making available or exporting relevant products.", "id": "eudr-trd-non-sme-trader-register", "kind": "submission", "level": "company", "timing": "before-market", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 5(2)" }, { "text": "Collect and keep the name, registered trade name or trade mark, postal address, email address and, if available, web address of your suppliers and, where the supplier is an operator, the reference numbers of the due diligence statements or the declaration identifiers, plus the same details of the downstream operators or traders you supply.", "id": "eudr-trd-collect-keep-name", "kind": "data", "level": "lot", "timing": "per-lot", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 5(3)" }, { "text": "Keep that information for at least five years from placing, making available or export and provide it to the competent authorities on request.", "id": "eudr-trd-keep-information-least", "kind": "standing", "level": "company", "timing": "ongoing", "sharedKey": "record-keeping-5y", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 5(4)" }, { "text": "Immediately inform the competent authorities of the Member States in which you placed or made the product available, and the downstream operators and traders you supplied, when relevant new information, including substantiated concerns, indicates that a product you placed or made available is at risk of non-compliance. As a non-SME trader, if before placing, making available or exporting you obtain or are made aware of relevant information indicating that a product is not compliant, immediately inform the competent authorities of the Member States in which you intend to place or make it available or from which you intend to export it; in the case of substantiated concerns, verify that due diligence was exercised and no or only a negligible risk was found, and do not place, make available or export the product unless the verification shows no or only a negligible risk.", "id": "eudr-trd-immediately-inform-competent", "kind": "submission", "level": "product", "timing": "on-event", "retired": "2026-09-24", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 5(5) and 5(6)" }, { "text": "Immediately inform the competent authorities of the Member States where you placed or made the product available, and the downstream operators and traders you supplied, when relevant new information, including substantiated concerns, indicates that the product is at risk of non-compliance.", "id": "eudr-trd-inform-risk-non-compliance", "kind": "submission", "level": "product", "timing": "on-event", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 5(5)" }, { "text": "As a non-SME trader, if you learn before placing, making available or exporting that a product is not compliant, immediately inform the competent authorities concerned; on substantiated concerns, verify that due diligence found no or only a negligible risk, and otherwise do not place, make available or export the product.", "id": "eudr-trd-verify-substantiated-concerns", "kind": "verification", "level": "product", "timing": "on-event", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 5(6)" }, { "text": "Offer all necessary assistance to the competent authorities for checks, including access to premises, documentation and records.", "id": "eudr-trd-offer-necessary-assistance", "kind": "standing", "level": "company", "timing": "ongoing", "sharedKey": "authority-cooperation", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 5(7)" } ], "producer": [ { "text": "Submit a one-time simplified declaration in the EU information system before placing relevant products on the market or exporting them; you receive a declaration identifier and may update the declaration after major changes.", "id": "eudr-prod-submit-one-time-simplified", "kind": "submission", "level": "company", "timing": "before-market", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 4a(2) and 4a(3)" }, { "text": "Provide the Annex III information: name, address and EORI number where applicable, the HS code and description of the products, the estimated annual quantity, the country of production and the geolocation or postal address of all plots of land or cattle establishments, and the declaration that due diligence will be exercised.", "id": "eudr-prod-provide-annex-iii", "kind": "data", "level": "company", "timing": "before-market", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 4a(3) and Annex III" }, { "text": "You are exempt from the per-product due diligence statement, from the five-year record of statements and from Article 4(4)(c); the prohibition in Article 3 and the duty to exercise due diligence under Article 4(1) still apply.", "id": "eudr-prod-exempt-per-product-due", "kind": "status", "level": "product", "timing": "before-market", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 4a(1) and Art. 4(1)" }, { "text": "You may replace the geolocation of plots with the postal address of all plots of land or of the establishment where the commodities were produced.", "id": "eudr-prod-replace-geolocation-plots", "kind": "data", "level": "company", "timing": "before-market", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 4a(5)" }, { "text": "Where all Annex III information already exists in a Union or Member State system or database, no simplified declaration is required; the Member State makes the information available in the EU information system, and you may place products only after a declaration identifier has been assigned.", "id": "eudr-prod-simplified-declaration-required", "kind": "status", "level": "company", "timing": "before-market", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 4a(4)" }, { "text": "If you are a natural person or a microenterprise, you may mandate the next downstream operator or trader that is not a natural person or a microenterprise to submit the simplified declaration on your behalf, while retaining responsibility for compliance.", "id": "eudr-prod-mandate-next-downstream", "kind": "decision", "level": "company", "timing": "before-market", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 6(3)" } ] }, "requirements": [ { "id": "eudr-op-exercise-due-diligence", "role": "operator", "kind": "procedure", "level": "lot", "timing": "per-lot", "text": "Exercise due diligence for all relevant products before placing them on the market or exporting them: collect the information required by Article 9, assess the risk under Article 10 and mitigate it under Article 11.", "article": "Art. 4(1) and Art. 8", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-op-place-relevant-product", "role": "operator", "kind": "submission", "level": "lot", "timing": "per-lot", "text": "Do not place a relevant product on the market or export it without first making a due diligence statement available to the competent authorities through the EU information system, containing the Annex II information and a declaration that due diligence was exercised and no or only a negligible risk was found.", "article": "Art. 4(2) and Annex II", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-op-making-statement-available", "role": "operator", "kind": "standing", "level": "company", "timing": "ongoing", "sharedKey": "record-keeping-5y", "retired": "2026-09-24", "text": "By making the statement available you assume responsibility for the product's compliance with Article 3; keep a record of each due diligence statement for five years from submission.", "article": "Art. 4(3)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-op-assume-responsibility-statement", "role": "operator", "kind": "status", "level": "product", "timing": "before-market", "text": "By making the due diligence statement available to the competent authorities you assume responsibility for the product's compliance with Article 3.", "article": "Art. 4(3)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-op-keep-statements-five-years", "role": "operator", "kind": "standing", "level": "company", "timing": "ongoing", "sharedKey": "record-keeping-5y", "text": "Keep a record of each due diligence statement for five years from its submission.", "article": "Art. 4(3)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-op-collect-organise-keep", "role": "operator", "kind": "data", "level": "lot", "timing": "per-lot", "text": "Collect, organise and keep for five years, with evidence: a product description including the common and scientific species names for wood, the quantity, the country of production, the geolocation of all plots of land (or cattle establishments) with the date or time range of production, the names, postal and email addresses of suppliers and customers, and adequately conclusive and verifiable information that the product is deforestation-free and was produced legally.", "article": "Art. 9(1)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-op-provide-geolocation-latitude", "role": "operator", "kind": "data", "level": "lot", "timing": "per-lot", "text": "Provide geolocation as latitude and longitude with at least six decimal digits; plots of more than four hectares used for commodities other than cattle must be described by polygons. Any deforestation or forest degradation on a plot disqualifies all commodities and products from it.", "article": "Art. 2(28) and Art. 9(1)(d)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-op-carry-out-risk", "role": "operator", "kind": "procedure", "level": "product", "timing": "before-market", "text": "Carry out a risk assessment against the Article 10(2) criteria, including the country's risk classification, the presence of forests and indigenous peoples, supply chain complexity and the risk of circumvention; place the product only where the assessment reveals no or only a negligible risk; document and review the assessment at least annually.", "article": "Art. 10", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-op-adopt-mitigation-measures", "role": "operator", "kind": "decision", "level": "product", "timing": "before-market", "retired": "2026-09-24", "text": "Where the risk is not negligible, adopt mitigation measures before placing the product, such as requiring additional information, independent surveys or audits; keep adequate policies, controls and procedures, and as a non-SME operator appoint a compliance officer at management level and an independent audit function; document mitigation decisions and review them at least annually.", "article": "Art. 11", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-op-adopt-risk-mitigation", "role": "operator", "kind": "decision", "level": "product", "timing": "before-market", "text": "Where the risk assessment reveals a non-negligible risk, adopt mitigation measures before placing the product, such as requiring additional information, independent surveys or audits, and document the mitigation decisions and review them at least annually.", "article": "Art. 11(1) and Art. 11(3)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-op-keep-mitigation-policies", "role": "operator", "kind": "standing", "level": "company", "timing": "ongoing", "text": "Keep adequate and proportionate policies, controls and procedures to mitigate and manage the risk of non-compliance, and as a non-SME operator appoint a compliance officer at management level and an independent audit function.", "article": "Art. 11(2)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-op-establish-keep-date", "role": "operator", "kind": "standing", "level": "company", "timing": "ongoing", "retired": "2026-09-24", "text": "Establish and keep up to date a due diligence system, review it at least once a year, keep a record of updates and all due diligence documentation for at least five years, and make it available to the competent authorities on request.", "article": "Art. 12(1), 12(2) and 12(5)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-op-keep-due-diligence-system", "role": "operator", "kind": "standing", "level": "company", "timing": "periodic", "text": "Establish and keep up to date a due diligence system, and review it at least once a year.", "article": "Art. 12(1) and Art. 12(2)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-op-keep-due-diligence-records", "role": "operator", "kind": "standing", "level": "company", "timing": "ongoing", "sharedKey": "record-keeping-5y", "text": "Keep a record of the updates to the due diligence system and all documentation related to due diligence for at least five years, and make it available to the competent authorities on request.", "article": "Art. 12(2) and Art. 12(5)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-op-operator-sme-natural", "role": "operator", "kind": "evidence", "level": "company", "timing": "periodic", "text": "As an operator that is not an SME or a natural person, report publicly every year, including on the internet, on the due diligence system and the steps taken to fulfil the due diligence obligations, including a summary of products and countries, the conclusions of the risk assessment and the mitigation measures.", "article": "Art. 12(3) and 12(4)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-op-use-simplified-due", "role": "operator", "kind": "decision", "level": "product", "timing": "before-market", "text": "Where all relevant commodities and products come from countries classified as low risk, you may use simplified due diligence and skip the risk assessment and mitigation steps, after assessing supply chain complexity and the risk of circumvention or mixing; keep documentation showing that risk is negligible and fall back to full due diligence as soon as any risk information arises.", "article": "Art. 13", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-op-immediately-inform-competent", "role": "operator", "kind": "submission", "level": "product", "timing": "on-event", "retired": "2026-09-24", "text": "Immediately inform the competent authorities and the downstream operators and traders you supplied when new information, including substantiated concerns, indicates that a product you placed on the market is at risk of non-compliance; give the authorities all necessary assistance for checks, including access to premises, documents and records.", "article": "Art. 4(5) and 4(6)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-op-inform-risk-non-compliance", "role": "operator", "kind": "submission", "level": "product", "timing": "on-event", "text": "Immediately inform the competent authorities and the downstream operators and traders you supplied when new information, including substantiated concerns, indicates that a product you placed on the market is at risk of non-compliance.", "article": "Art. 4(5)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-op-offer-necessary-assistance", "role": "operator", "kind": "standing", "level": "company", "timing": "ongoing", "sharedKey": "authority-cooperation", "text": "Offer all necessary assistance to the competent authorities for checks, including access to premises, documentation and records.", "article": "Art. 4(6)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-op-communicate-reference-numbers", "role": "operator", "kind": "data", "level": "lot", "timing": "per-lot", "text": "Communicate the reference numbers of your due diligence statements, or the declaration identifiers, to the downstream operators and traders further down the supply chain.", "article": "Art. 4(7)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-op-mandate-authorised-representative", "role": "operator", "kind": "decision", "level": "company", "timing": "before-market", "text": "You may mandate an authorised representative established in the Union to submit the statement on your behalf, but you retain responsibility for the product's compliance.", "article": "Art. 6(1)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-imp-first-natural-legal", "role": "importer", "kind": "status", "level": "company", "timing": "before-market", "text": "When a person established outside the Union places relevant products on the market, the first natural or legal person established in the Union who makes them available is deemed the operator and carries every operator obligation, including due diligence and the due diligence statement.", "article": "Art. 7 and Art. 4", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-imp-include-eori-number", "role": "importer", "kind": "submission", "level": "lot", "timing": "per-lot", "text": "For products released for free circulation or exported, include your EORI number in the information system registration and in the due diligence statement; the products are subject to the customs controls of Chapter 4.", "article": "Art. 33(2)(a), Annex II(1) and Art. 26", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-mfr-place-market-make", "role": "manufacturer", "kind": "verification", "level": "product", "timing": "before-market", "text": "Place on the market, make available or export relevant products only when you hold the Article 5(3) information; your downstream operator status depends on every relevant product you use being covered by a due diligence statement or simplified declaration, otherwise you are an operator.", "article": "Art. 5(1) and Art. 2(15b)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-mfr-non-sme-downstream-operator", "role": "manufacturer", "kind": "submission", "level": "company", "timing": "before-market", "text": "As a non-SME downstream operator, register in the EU information system before placing, making available or exporting relevant products.", "article": "Art. 5(2)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-mfr-collect-keep-name", "role": "manufacturer", "kind": "data", "level": "lot", "timing": "per-lot", "text": "Collect and keep the name, registered trade name or trade mark, postal address, email address and, if available, web address of your suppliers and, where the supplier is an operator, the reference numbers of the due diligence statements or the declaration identifiers, plus the same details of the downstream operators or traders you supply.", "article": "Art. 5(3)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-mfr-keep-information-least", "role": "manufacturer", "kind": "standing", "level": "company", "timing": "ongoing", "sharedKey": "record-keeping-5y", "text": "Keep that information for at least five years from placing, making available or export and provide it to the competent authorities on request.", "article": "Art. 5(4)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-mfr-immediately-inform-competent", "role": "manufacturer", "kind": "submission", "level": "product", "timing": "on-event", "retired": "2026-09-24", "text": "Immediately inform the competent authorities and the parties you supplied when new information indicates that a product you placed or made available is at risk of non-compliance; as a non-SME, inform the authorities before placing a product you know to be non-compliant, verify that due diligence was exercised when there is a substantiated concern, and do not place the product unless the verification shows no or only a negligible risk.", "article": "Art. 5(5) and 5(6)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-mfr-inform-risk-non-compliance", "role": "manufacturer", "kind": "submission", "level": "product", "timing": "on-event", "text": "Immediately inform the competent authorities and the parties you supplied when new information indicates that a product you placed or made available is at risk of non-compliance.", "article": "Art. 5(5)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-mfr-verify-substantiated-concerns", "role": "manufacturer", "kind": "verification", "level": "product", "timing": "on-event", "text": "As a non-SME, inform the authorities before placing a product you know to be non-compliant, verify that due diligence was exercised when there is a substantiated concern, and do not place the product unless the verification shows no or only a negligible risk.", "article": "Art. 5(6)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-mfr-offer-necessary-assistance", "role": "manufacturer", "kind": "standing", "level": "company", "timing": "ongoing", "sharedKey": "authority-cooperation", "text": "Offer all necessary assistance to the competent authorities for checks, including access to premises, documentation and records.", "article": "Art. 5(7)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-trd-make-relevant-products", "role": "trader", "kind": "verification", "level": "product", "timing": "before-market", "text": "Make relevant products available on the market only when you hold the Article 5(3) supplier and customer information.", "article": "Art. 5(1)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-trd-non-sme-trader-register", "role": "trader", "kind": "submission", "level": "company", "timing": "before-market", "text": "As a non-SME trader, register in the EU information system before placing, making available or exporting relevant products.", "article": "Art. 5(2)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-trd-collect-keep-name", "role": "trader", "kind": "data", "level": "lot", "timing": "per-lot", "text": "Collect and keep the name, registered trade name or trade mark, postal address, email address and, if available, web address of your suppliers and, where the supplier is an operator, the reference numbers of the due diligence statements or the declaration identifiers, plus the same details of the downstream operators or traders you supply.", "article": "Art. 5(3)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-trd-keep-information-least", "role": "trader", "kind": "standing", "level": "company", "timing": "ongoing", "sharedKey": "record-keeping-5y", "text": "Keep that information for at least five years from placing, making available or export and provide it to the competent authorities on request.", "article": "Art. 5(4)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-trd-immediately-inform-competent", "role": "trader", "kind": "submission", "level": "product", "timing": "on-event", "retired": "2026-09-24", "text": "Immediately inform the competent authorities of the Member States in which you placed or made the product available, and the downstream operators and traders you supplied, when relevant new information, including substantiated concerns, indicates that a product you placed or made available is at risk of non-compliance. As a non-SME trader, if before placing, making available or exporting you obtain or are made aware of relevant information indicating that a product is not compliant, immediately inform the competent authorities of the Member States in which you intend to place or make it available or from which you intend to export it; in the case of substantiated concerns, verify that due diligence was exercised and no or only a negligible risk was found, and do not place, make available or export the product unless the verification shows no or only a negligible risk.", "article": "Art. 5(5) and 5(6)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-trd-inform-risk-non-compliance", "role": "trader", "kind": "submission", "level": "product", "timing": "on-event", "text": "Immediately inform the competent authorities of the Member States where you placed or made the product available, and the downstream operators and traders you supplied, when relevant new information, including substantiated concerns, indicates that the product is at risk of non-compliance.", "article": "Art. 5(5)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-trd-verify-substantiated-concerns", "role": "trader", "kind": "verification", "level": "product", "timing": "on-event", "text": "As a non-SME trader, if you learn before placing, making available or exporting that a product is not compliant, immediately inform the competent authorities concerned; on substantiated concerns, verify that due diligence found no or only a negligible risk, and otherwise do not place, make available or export the product.", "article": "Art. 5(6)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-trd-offer-necessary-assistance", "role": "trader", "kind": "standing", "level": "company", "timing": "ongoing", "sharedKey": "authority-cooperation", "text": "Offer all necessary assistance to the competent authorities for checks, including access to premises, documentation and records.", "article": "Art. 5(7)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-prod-submit-one-time-simplified", "role": "producer", "kind": "submission", "level": "company", "timing": "before-market", "text": "Submit a one-time simplified declaration in the EU information system before placing relevant products on the market or exporting them; you receive a declaration identifier and may update the declaration after major changes.", "article": "Art. 4a(2) and 4a(3)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-prod-provide-annex-iii", "role": "producer", "kind": "data", "level": "company", "timing": "before-market", "text": "Provide the Annex III information: name, address and EORI number where applicable, the HS code and description of the products, the estimated annual quantity, the country of production and the geolocation or postal address of all plots of land or cattle establishments, and the declaration that due diligence will be exercised.", "article": "Art. 4a(3) and Annex III", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-prod-exempt-per-product-due", "role": "producer", "kind": "status", "level": "product", "timing": "before-market", "text": "You are exempt from the per-product due diligence statement, from the five-year record of statements and from Article 4(4)(c); the prohibition in Article 3 and the duty to exercise due diligence under Article 4(1) still apply.", "article": "Art. 4a(1) and Art. 4(1)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-prod-replace-geolocation-plots", "role": "producer", "kind": "data", "level": "company", "timing": "before-market", "text": "You may replace the geolocation of plots with the postal address of all plots of land or of the establishment where the commodities were produced.", "article": "Art. 4a(5)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-prod-simplified-declaration-required", "role": "producer", "kind": "status", "level": "company", "timing": "before-market", "text": "Where all Annex III information already exists in a Union or Member State system or database, no simplified declaration is required; the Member State makes the information available in the EU information system, and you may place products only after a declaration identifier has been assigned.", "article": "Art. 4a(4)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "id": "eudr-prod-mandate-next-downstream", "role": "producer", "kind": "decision", "level": "company", "timing": "before-market", "text": "If you are a natural person or a microenterprise, you may mandate the next downstream operator or trader that is not a natural person or a microenterprise to submit the simplified declaration on your behalf, while retaining responsibility for compliance.", "article": "Art. 6(3)", "sourceUrl": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" } ], "requirementsHash": "7c7e3f6bd5718f7d", "penalties": { "text": "Member States lay down the penalties, which must be effective, proportionate and dissuasive and must include: fines proportionate to the environmental damage and the value of the products, calculated to deprive those responsible of the economic benefit and increasing for repeated infringements, with a maximum for legal persons of at least 4 % of total annual EU-wide turnover in the preceding financial year; confiscation of the products and of the revenues from them; exclusion for up to 12 months from public procurement and public funding; a temporary ban on placing, making available or exporting relevant products for serious or repeated infringements; and a ban on using simplified due diligence, likewise for serious or repeated infringements. Final judgments against legal persons are notified to the Commission within 30 days and published on its website with the name of the company, the date, a summary of the infringement and the penalty.", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 25" }, "checklist": [ "Map every product line to Annex I by CN code and record which commodity it contains, was fed with or was made using.", "Decide your role for each product: operator (first to place it on the EU market or to export it), downstream operator, trader, or micro or small primary operator.", "Fix your application date: 30 December 2026, or 30 June 2027 if you are a micro or small operator established by 31 December 2024 and the product was not covered by the EU Timber Regulation.", "Register in the EU information system if you are an operator, a non-SME downstream operator or a non-SME trader.", "Collect from suppliers the geolocation of every plot of land (polygons above four hectares), the production dates, the country of production and evidence of legal production.", "Check the Commission's country risk classification and run a risk assessment against the Article 10 criteria; use simplified due diligence only where every commodity comes from a low-risk country.", "Mitigate any non-negligible risk before placing the product on the market, document the decision and review it at least once a year.", "Submit a due diligence statement for each product before placing it on the market or exporting it, and pass the reference number to your customers.", "Set up a due diligence system with five-year record keeping; as a non-SME operator appoint a compliance officer, an independent audit function and publish an annual report.", "Prepare to assist competent authorities during checks and to notify them and your customers immediately when new risk information appears." ], "faq": [ { "q": "When does the EUDR apply?", "a": "The regulation entered into force on 29 June 2023, but its obligations have been postponed twice. Articles 3 to 13, 16 to 24, 26, 31 and 32 now apply from 30 December 2026. Operators that are natural persons or micro or small undertakings established by 31 December 2024 have until 30 June 2027, except for products that were already covered by the annex to the EU Timber Regulation.", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 38" }, { "q": "Which products are covered?", "a": "Products listed in Annex I that contain, have been fed with or have been made using cattle, cocoa, coffee, oil palm, rubber, soya or wood: from live cattle, leather, chocolate, coffee and palm oil to tyres, soya meal, sawn wood, panels, pallets, paper, wooden furniture and prefabricated wooden buildings. Goods produced entirely from material that has completed its life cycle as waste are excluded, as is packing material used exclusively to support, protect or carry another product.", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 1(1) and Annex I" }, { "q": "What does deforestation-free mean?", "a": "The commodities must have been produced on land that has not been subject to deforestation after 31 December 2020, and wood must have been harvested from the forest without inducing forest degradation after that date. Deforestation means the conversion of forest to agricultural use, whether human-induced or not, and a forest is land spanning more than 0,5 hectares with trees higher than 5 metres and a canopy cover of more than 10 %, or trees able to reach those thresholds in situ, excluding land that is predominantly under agricultural or urban land use.", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 2(3), 2(4) and 2(13)" }, { "q": "Am I an operator, a downstream operator or a trader?", "a": "You are an operator if you are the first to place a relevant product on the Union market or you export it; when a non-EU company places the product, the first EU-established company that makes it available is deemed the operator. You are a downstream operator if you place or export products made using relevant products that are all already covered by a due diligence statement or simplified declaration. Anyone else who makes the products available further down the chain is a trader.", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 2(15), 2(15b), 2(17) and Art. 7" }, { "q": "What is a due diligence statement and where do I submit it?", "a": "It is the electronic statement an operator makes available to the competent authorities through the EU information system before placing a product on the market or exporting it, containing the Annex II information (operator, HS code, quantity, country of production and geolocation) and a declaration that due diligence was exercised and no or only a negligible risk was found. The Commission had to establish the information system by 30 December 2024 and launched it on 4 December 2024.", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 4(2), Art. 33(1) and Annex II; https://environment.ec.europa.eu/topics/forests/deforestation/regulation-deforestation-free-products_en" }, { "q": "Do I really need coordinates for every plot of land?", "a": "Yes for operators: the geolocation of all plots where the commodities were produced, as latitude and longitude with at least six decimal digits, and polygons for plots of more than four hectares other than for cattle; for cattle the geolocation refers to the establishments where the animals were kept. Only micro or small primary operators in low-risk countries may replace geolocation with the postal address of the plots or establishment.", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 2(28), Art. 9(1)(d) and Art. 4a(5)" }, { "q": "What are the penalties for non-compliance?", "a": "Member States set the penalties, which must include fines with a maximum of at least 4 % of the company's total annual EU-wide turnover, confiscation of the products and of the revenues from them, exclusion from public procurement and public funding for up to 12 months, and temporary bans on placing, making available or exporting relevant products. Final judgments against companies are published on the Commission's website.", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 25" }, { "q": "What happens to the EU Timber Regulation?", "a": "Regulation (EU) No 995/2010 is repealed with effect from 30 December 2026. It continues to apply until 31 December 2029 to timber and timber products produced before 29 June 2023 and placed on the market from 30 December 2026; from 31 December 2029 such timber must comply with Article 3 of the EUDR.", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 37" } ], "changelog": [ { "date": "2027-06-30", "kind": "applies", "title": "Application for micro and small operators", "summary": "Operators that are natural persons or micro or small undertakings established by 31 December 2024 must comply from this date, except for products covered by the annex to the EU Timber Regulation.", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 38(3)" }, { "date": "2026-12-30", "kind": "applies", "title": "Obligations apply; EU Timber Regulation repealed", "summary": "Articles 3 to 13, 16 to 24, 26, 31 and 32 apply to operators, downstream operators and traders, and Regulation (EU) No 995/2010 is repealed.", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 38(2) and Art. 37(1)" }, { "date": "2025-12-26", "kind": "amendment", "title": "Regulation (EU) 2025/2650 in force", "summary": "Second 12-month postponement to 30 December 2026 and 30 June 2027, with the EU Timber Regulation repeal moved to 30 December 2026; amended Article 2 definitions (operator, trader, commercial activity, authorised representative, SMEs) and added the definitions of micro or small primary operator and downstream operator; new downstream operator role with information duties; one-time simplified declaration for micro or small primary operators in low-risk countries (Article 4a and Annex III); registration of non-SME downstream operators and traders; simplification review by 30 April 2026; the chapter 49 line (printed books, newspapers and other products of the printing industry, of paper) deleted from Annex I and point 4 deleted from Annex II.", "source": "https://eur-lex.europa.eu/eli/reg/2025/2650/oj · Art. 1 and Art. 2" }, { "date": "2024-12-26", "kind": "amendment", "title": "Regulation (EU) 2024/3234 in force", "summary": "First 12-month postponement of the application dates to 30 December 2025 and 30 June 2026; Article 37 replaced so that the repeal of Regulation (EU) No 995/2010 (EU Timber Regulation) moved to 30 December 2025, with that regulation continuing to apply until 31 December 2028 to timber produced before 29 June 2023 and placed on the market from 30 December 2025; deadline for the country risk classification moved to 30 June 2025.", "source": "https://eur-lex.europa.eu/eli/reg/2024/3234/oj · Art. 1 and Art. 2" }, { "date": "2024-12-04", "kind": "guidance", "title": "EU information system launched", "summary": "The Commission launched the Article 33 information system in which due diligence statements are submitted; user registration opened in November 2024.", "source": "https://environment.ec.europa.eu/topics/forests/deforestation/regulation-deforestation-free-products_en" }, { "date": "2023-06-29", "kind": "in-force", "title": "Regulation (EU) 2023/1115 enters into force", "summary": "Twenty days after publication in OJ L 150 of 9 June 2023; all countries assigned a standard level of risk on the same day.", "source": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 · Art. 38(1) and Art. 29(2)" } ], "sources": [ { "label": "EUR-Lex: Regulation (EU) 2023/1115, consolidated text of 26 December 2025", "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226" }, { "label": "EUR-Lex: Regulation (EU) 2023/1115 as published (CELEX 32023R1115)", "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1115" }, { "label": "EUR-Lex: Regulation (EU) 2024/3234 amending the date of application", "url": "https://eur-lex.europa.eu/eli/reg/2024/3234/oj" }, { "label": "EUR-Lex: Regulation (EU) 2025/2650 amending certain obligations of operators and traders", "url": "https://eur-lex.europa.eu/eli/reg/2025/2650/oj" }, { "label": "EUR-Lex: Regulation (EU) No 995/2010 (EU Timber Regulation), annex of covered timber products", "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32010R0995" }, { "label": "European Commission: Regulation on deforestation-free products", "url": "https://environment.ec.europa.eu/topics/forests/deforestation/regulation-deforestation-free-products_en" } ], "reviewer": { "name": "Conphora compliance team", "role": "Compliance editors, Conphora" }, "reviewedAt": "2026-09-24", "nextReview": "2026-12-30", "links": { "tools": [], "courses": [], "related": { "en": "/regulations/eudr/", "dk": "/dk/eu-regulativer/eudr/" } } }