EUDR in plain terms
The EUDR, formally Regulation (EU) 2023/1115 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, sets one rule: cattle, cocoa, coffee, oil palm, rubber, soya and wood, and the products listed in its Annex I, may not be placed on the EU market, made available or exported unless they are deforestation-free, were produced in accordance with the relevant legislation of the country of production, and are covered by a due diligence statement or a simplified declaration (Art. 3). “Deforestation-free” is measured against a fixed date: the land must not have been subject to deforestation after 31 December 2020, and wood must have been harvested without inducing forest degradation after that date (Art. 2(13)).
The regulation replaces the EU Timber Regulation and extends its logic from timber to six agricultural commodities (Art. 37). It is data-heavy by design: the company that first places a product on the market must know the geolocation of every plot of land where the commodity was grown, harvested or raised (Art. 9(1)(d)). It entered into force on 29 June 2023 (Art. 38(1)), and after two amending regulations, Regulation (EU) 2024/3234 and Regulation (EU) 2025/2650, its obligations apply from 30 December 2026, with a later date of 30 June 2027 for micro and small operators established by 31 December 2024 (Art. 38(2) and (3)).
If you make or sell furniture, lifestyle goods or packaging, this regulation almost certainly touches you. Wood is one of the seven commodities, and Annex I reaches far down the chain: sawn wood, plywood and fibreboard, wooden pallets and crates, joinery, wooden tableware, frames, pulp, paper and paperboard, wooden seats and furniture, and prefabricated wooden buildings. Leather of cattle, tyres and chocolate are in the same annex. A brand that thinks of itself as a “furniture company” rather than a “timber importer” is still in scope, and the obligations attach to the first company that places the product on the EU market (Art. 2(15) and Art. 7).
Official text Read the regulation on EUR-Lex: Regulation (EU) 2023/1115 (CELEX 32023R1115); the consolidated text of 26 December 2025 includes both amendments.
Scope
The regulation applies to “relevant products”: the goods listed in Annex I, identified by their Combined Nomenclature codes, that contain, have been fed with or have been made using one of the seven “relevant commodities” (Art. 1(1) and Art. 2(1) and (2)). The decisive question is not what your company calls itself but whether the product’s CN code appears in the annex. Two carve-outs matter for lifestyle and packaging businesses: the regulation does not apply to goods produced entirely from material that has completed its life cycle and would otherwise be discarded as waste, and the packaging lines of the annex exclude packing material used exclusively to support, protect or carry another product placed on the market (Annex I). Products produced before the regulation entered into force are outside its scope, with a transition for timber under the EU Timber Regulation (Art. 1(2) and Art. 37).
Since Regulation (EU) 2025/2650 the regulation distinguishes four roles rather than two:
- An operator is any natural or legal person who, in the course of a commercial activity, places relevant products on the market, meaning the first making available on the Union market, or exports them (Art. 2(15) and (16)). When a company outside the EU places the product, the first EU-established company that makes it available is deemed the operator (Art. 7). Operators carry the full due diligence burden.
- A downstream operator places on the market or exports products made using relevant products that are all already covered by a due diligence statement or simplified declaration, and has information duties only (Art. 2(15b) and Art. 5).
- A trader is anyone else in the supply chain who makes relevant products available on the market, with the same information duties as a downstream operator (Art. 2(17) and Art. 5).
- A micro or small primary operator is an operator that is a natural person or micro or small undertaking established in a country classified as low risk and that places or exports relevant products it has itself grown, harvested, obtained or raised on plots of land or cattle establishments located in that country; it files a one-time simplified declaration instead of due diligence statements (Art. 2(15a) and Art. 4a).
Company size matters at two points. Non-SME operators have extra governance and reporting duties, and non-SME downstream operators and traders must register in the EU information system and verify due diligence when a substantiated concern arises (Art. 5(2) and (6), Art. 11(2) and Art. 12(3)). Micro and small operators established by 31 December 2024 get the later application date of 30 June 2027, unless their products were already covered by the annex to the EU Timber Regulation (Art. 38(3)). SMEs are defined by reference to Article 3 of Directive 2013/34/EU (Art. 2(30)).
What you must do
Due diligence before placing on the market
An operator must exercise due diligence for every relevant product before placing it on the market or exporting it (Art. 4(1) and Art. 8(1)). Due diligence has three steps: collecting the information, documents and data required by Article 9, assessing the risk under Article 10 and, where the risk is not negligible, mitigating it under Article 11 (Art. 8(2)). Products may only move when the assessment reveals no or only a negligible risk of non-compliance (Art. 10(1)).
The information to collect
For each product the operator collects, organises and keeps for five years: a description including the trade name, product type and, for wood, the common and full scientific species names; the quantity in kilograms of net mass where the product enters or leaves the market; the country of production; the geolocation of all plots of land where the commodity was produced and the date or time range of production, or for cattle the geolocation of all establishments where the animals were kept; the name, postal address and email address of every supplier and every customer; and adequately conclusive and verifiable information that the product is deforestation-free and was produced legally (Art. 9(1)). Geolocation means latitude and longitude with at least six decimal digits, and polygons for plots of more than four hectares used for commodities other than cattle (Art. 2(28)). Any deforestation or forest degradation on a plot automatically disqualifies everything produced on it (Art. 9(1)(d)).
Risk assessment and mitigation
The risk assessment weighs the Commission’s classification of the country of production as low, standard or high risk (Art. 29), the presence of forests and of indigenous peoples, the prevalence of deforestation, the reliability of the information, concerns such as corruption, document falsification or armed conflict, the complexity of the supply chain, the risk of circumvention or mixing with products of unknown origin, substantiated concerns, and information from certification schemes provided it meets the Article 9 requirements (Art. 10(2)). Assessments are documented and reviewed at least annually (Art. 10(4)). Where the risk is not negligible, the operator adopts mitigation measures before placing the product, such as requiring additional documents or carrying out independent surveys or audits, and may support suppliers, in particular smallholders, through capacity building (Art. 11(1)). Every operator needs adequate policies, controls and procedures; non-SME operators must in addition appoint a compliance officer at management level and have an independent audit function (Art. 11(2)). Where all commodities come from countries classified as low risk, simplified due diligence lets the operator skip the assessment and mitigation steps after checking supply chain complexity and the risk of circumvention, with documentation available on request (Art. 13).
The due diligence statement
Before placing a product on the market or exporting it, the operator makes a due diligence statement available to the competent authorities through the EU information system (Art. 4(2) and Art. 33). The statement contains the Annex II information, the operator’s name, address and EORI number where applicable, the HS code, description and quantity, the country of production and the geolocation of all plots, and the declaration that due diligence was exercised and no or only a negligible risk was found (Annex II). By submitting it the operator assumes responsibility for compliance and keeps a record of the statement for five years (Art. 4(3)). The reference number is passed to downstream operators and traders (Art. 4(7)), who keep it with their supplier records (Art. 5(3)). An authorised representative may submit the statement, but responsibility stays with the operator (Art. 6).
Due diligence system, records and reporting
Operators establish and keep up to date a due diligence system, review it at least once a year, update it when new developments arise, and keep all due diligence documentation for at least five years (Art. 12(1), (2) and (5)). Operators that are not SMEs or natural persons report publicly every year, including on the internet, on their system and the steps taken, with a summary of products, quantities and countries, the conclusions of the risk assessment and the mitigation measures; companies already reporting under other EU value chain due diligence acts may report there (Art. 12(3) and (4)).
Downstream operators and traders
Downstream operators and traders may place, make available or export relevant products only when they hold the required information: the identity, address and email address of their suppliers together with the reference numbers of the due diligence statements or declaration identifiers where the supplier is an operator, and the identity of the downstream operators or traders they supply (Art. 5(1) and (3)). They keep this for at least five years and provide it on request (Art. 5(4)). Non-SME downstream operators and traders also register in the information system before trading, inform the authorities before placing a product they know to be non-compliant, and verify that due diligence was exercised when a substantiated concern arises (Art. 5(2) and (6)). Everyone in the chain must inform the competent authorities and their customers immediately when new information indicates a risk, and assist the authorities during checks (Art. 4(5) and (6), Art. 5(5) and (7)).
Micro or small primary operators
A micro or small primary operator submits a one-time simplified declaration with the Annex III information in the information system before placing products on the market or exporting them, receives a declaration identifier, and may replace geolocation with the postal address of its plots or establishment (Art. 4a(2), (3) and (5)). Where all that information already exists in a Union or national database, the Member State makes it available in the information system and no separate declaration is needed, though products may only move once an identifier has been assigned (Art. 4a(4)). The exemption covers the per-product statement, the record of statements and Article 4(4)(c); the prohibition in Article 3 and the duty to exercise due diligence remain (Art. 4a(1)).
Enforcement and penalties
Each Member State designates one or more competent authorities to enforce the regulation (Art. 14(1)). Their checks follow a risk-based plan with minimum annual quotas: at least 9 % of the operators, non-SME downstream operators and non-SME traders sourcing from high-risk countries, and 9 % of the quantity of those products; at least 3 % of those sourcing from standard-risk countries; and at least 1 % of those sourcing from low-risk countries, calculated per commodity (Art. 16). Checks on operators cover the due diligence system, the statements and the underlying evidence, and the authorities may take interim measures and order corrective action (Art. 18, Art. 23 and Art. 24). Products released for free circulation or exported are additionally subject to customs controls, and the reference number of the due diligence statement, or the declaration identifier for micro or small primary operators, must be made available to customs before release for free circulation or export (Art. 26(4)). Anyone may submit a substantiated concern to a competent authority (Art. 31).
Penalties are set nationally but must be effective, proportionate and dissuasive, and the regulation prescribes the toolkit: fines proportionate to the environmental damage and the value of the products, calculated to deprive those responsible of the economic benefit and rising 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 gained 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 in the event of serious or repeated infringements; and a ban on using simplified due diligence (Art. 25(2)). Final judgments against legal persons are notified to the Commission within 30 days and published on its website with the company’s name, the date, a summary of the infringement and the penalty (Art. 25(3)).
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, consolidated text of 26 December 2025
- EUR-Lex: Regulation (EU) 2023/1115 as published (CELEX 32023R1115)
- EUR-Lex: Regulation (EU) 2024/3234 amending the date of application
- EUR-Lex: Regulation (EU) 2025/2650 amending certain obligations of operators and traders
- EUR-Lex: Regulation (EU) No 995/2010 (EU Timber Regulation), annex of covered timber products
- European Commission: Regulation on deforestation-free products
This guide is for general information and is not legal advice.