--- title: "A customer asks where our wood, cocoa or rubber comes from" description: "From 30 December 2026, the EU Deforestation Regulation (EU) 2023/1115 allows products such as wooden furniture, paper, chocolate or tyres on the market only if they are deforestation-free, legally produced and covered by a due diligence statement. Your customer will need the statement's reference number. Check your products against Annex I, establish your role, and collect origin data from suppliers now." type: "problem" url: "https://www.conphora.com/solutions/problem/deforestation-origin/" markdown: "https://www.conphora.com/solutions/problem/deforestation-origin.md" locale: "en" language: "en" updated: "2026-10-04" author: "Conphora compliance team" publisher: "Conphora" source: "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20260918" tags: ["EUDR", "sustainability-claims"] license: "Free to quote with attribution and a link to the page" --- # A customer asks where our wood, cocoa or rubber comes from From 30 December 2026, the EU Deforestation Regulation (EU) 2023/1115 allows products such as wooden furniture, paper, chocolate or tyres on the market only if they are deforestation-free, legally produced and covered by a due diligence statement. Your customer will need the statement's reference number. Check your products against Annex I, establish your role, and collect origin data from suppliers now. ## Why this happens The EU Deforestation Regulation, Regulation (EU) 2023/1115, governs placing and making available on the Union market, and export, of 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 (Article 1(1)). Annex I lists the products by customs code: among them wooden furniture, paper and paperboard articles, new tyres, rubber gloves, chocolate, coffee and soya products. Regulation (EU) 2025/2650 deleted the printed products of Chapter 49. Commission Delegated Regulation (EU) 2026/2102, in force since 18 September 2026, added products such as frozen cattle tongues, soluble coffee and palm oil derivatives including soap, removed leather, conveyor belts and other vulcanised rubber articles of headings 4010 and 4016, soya beans for sowing and aircraft and vehicle seats, and excluded samples, accompanying marketing material and packing material used with another product; some of the added entries apply only from 30 December 2027. [1][2][3] The core rule is in Article 3. A relevant product may be placed or made available on the market, or exported, only if it is deforestation-free, produced in accordance with the legislation of the country of production, and covered by a due diligence statement or a simplified declaration. Deforestation-free means produced on land not subject to deforestation after 31 December 2020, and for wood, harvested without inducing forest degradation after that date (Article 2(13)). [1] The regulation was amended by Regulation (EU) 2024/3234 and Regulation (EU) 2025/2650. The 2025 amendment introduced the downstream operator, who places on the market products made from products that are already covered by a statement (Article 2(15b)), and reshaped the duties of traders (Article 2(17)). Operators must pass the reference numbers of their due diligence statements, or the declaration identifiers, to the downstream operators and traders they supply (Article 4(7)). Downstream operators and traders must hold the names and addresses of their suppliers and customers, and the reference numbers when the supplier is an operator, and keep them for at least five years (Article 5(3) and (4)). [1] This is the information a business customer most often asks for. The geolocation of every plot of land is collected by the operator and goes to the authorities in the statement (Article 9(1)(d) and Annex II); the operator must pass on the reference numbers or declaration identifiers (Article 4(7)), and downstream operators and traders collect supplier and customer details (Article 5(3)). The text does not require plot data to travel down the chain. [1] The obligations apply from 30 December 2026, and from 30 June 2027 for operators that are natural persons or micro or small undertakings established as such by 31 December 2024, except for products covered by the Annex to Regulation (EU) No 995/2010 (Article 38(2) and (3)). The simplification review required by Article 34(1a) was published on 4 May 2026: the Commission did not consider it appropriate to propose further amendments to the text and relied on guidance, the information system and the Annex I delegated act (COM(2026) 191). EUR-Lex also lists a proposal of 10 September 2026, COM(2026) 661, that would exclude French Guiana from the regulation's territorial scope. [1][2][4] ## How to solve it 1. **Check each product against Annex I** Match the customs (CN) code of each product with the list in Annex I. Note the exclusions written into the list, such as used and second-hand products, packaging that only supports or protects another product, samples, and bamboo and rattan, and the entries that only apply from 30 December 2027. 2. **Work out your role for each product flow** The operator places the product on the EU market first or exports it and carries out due diligence. A downstream operator makes new covered products from products already covered by a statement. A trader only sells on. One company can hold different roles for different products. 3. **Ask suppliers for the data your role needs** As operator, collect the country of production, the geolocation of every plot of land, the production dates and evidence of legal production. If you buy from an operator, ask for the reference number of its due diligence statement for each delivery, plus its name and contact details. 4. **Answer the customer with what the regulation requires** Give the customer the reference numbers of the due diligence statements, or the declaration identifiers, for the products you supply, with your own identification. Whether you share more, such as plot data or certificates, is a matter for your agreement. 5. **Follow the dates and the changes to the text** The regulation has been amended three times, most recently its product list by a delegated act in force since 18 September 2026. The Commission's simplification review of May 2026 proposed no further change to the text. Watch the application dates, further delegated changes to Annex I and pending proposals. ## What you need to show - **Annex I classification for each product, with CN code** — Purchasing or customs (Regulation (EU) 2023/1115 Article 1(1) and Annex I) - **Due diligence statement reference numbers per delivery** — The operator that placed the product on the market (Regulation (EU) 2023/1115 Articles 4(7) and 5(3)(a)) - **Names, postal and email addresses of suppliers and customers** — Your own supplier and customer records (Regulation (EU) 2023/1115 Article 5(3)) ## If you do nothing - **No statement, no sale** — Relevant products may not be placed or made available on the market or exported unless they are deforestation-free, legally produced and covered by a due diligence statement or a simplified declaration (Regulation (EU) 2023/1115 Article 3). - **Customs need the reference number** — The reference number of the due diligence statement or the declaration identifier must be made available to customs before release for free circulation or export (Regulation (EU) 2023/1115 Article 26(4)). - **Fines, confiscation and exclusion** — Penalties must include fines with a maximum of at least 4 % of total annual Union-wide turnover for legal persons, confiscation of products and revenues, and temporary exclusion from public procurement for up to 12 months (Regulation (EU) 2023/1115 Article 25(2)). ## Questions ### When does the regulation apply? The obligations in Articles 3 to 13 apply from 30 December 2026. For operators that are natural persons or micro or small undertakings established as such by 31 December 2024, they apply from 30 June 2027, except for products that were covered by the Annex to the former Timber Regulation (EU) No 995/2010 (Regulation (EU) 2023/1115 Article 38(2) and (3)). ### Which commodities are covered? Cattle, cocoa, coffee, oil palm, rubber, soya and wood, and the products in Annex I that contain, were fed with or were made using them (Articles 1(1) and 2(1)). The rubber note covers Hevea brasiliensis, not synthetic rubber, and the wood note excludes bamboo and rattan (Annex I notes 3 and 4). ### Does recycled material count? Annex I excludes goods produced entirely from material that has completed its lifecycle and would otherwise have been discarded as waste under Directive 2008/98/EC. By-products of a manufacturing process that used non-waste material stay covered. ### Is the packaging around our product covered? Several wood and paper entries in Annex I exclude packing material and containers used exclusively to support, protect or carry another product and presented with it. Packaging sold as a product in its own right stays in scope (Delegated Regulation (EU) 2026/2102, recital 16). ## Regulations involved EUDR ## Sources 1. [Regulation (EU) 2023/1115 on deforestation-free products (consolidated text of 18 September 2026)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20260918) — EUR-Lex, 2026-10-04 2. [Regulation (EU) 2023/1115: document information, amendments and dates](https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32023R1115) — EUR-Lex, 2026-10-04 3. [Commission Delegated Regulation (EU) 2026/2102 amending Annex I to Regulation (EU) 2023/1115](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32026R2102) — EUR-Lex, 2026-10-04 4. [Report from the Commission: simplification review of Regulation (EU) 2023/1115, COM(2026) 191](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52026DC0191) — EUR-Lex, 2026-10-04