EUDR Supplier Requirements: Geolocation, DDS & Deadlines

If you supply wood, coffee, cocoa, rubber, palm oil, soy, cattle products — or things made from them — a customer has probably asked you about EUDR. The core of what they need is specific: proof of where your commodity was produced, and that it wasn't linked to deforestation. This guide explains what the regulation covers, what your customers will ask you for, who actually files the paperwork, and how the (repeatedly postponed) timeline now stands.

A note on dates before anything else: EUDR's application has now been postponed twice — most recently in December 2025 — and the details could shift again. This guide reflects the position as of mid-2026. For anything deadline-critical, check the European Commission's implementation page rather than relying on any article, including this one.

What EUDR is

The EU Deforestation Regulation (EUDR) bans placing certain commodities on the EU market — or exporting them from it — unless they are deforestation-free and legally produced. "Deforestation-free" means the land they came from wasn't deforested or degraded after 31 December 2020. "Legally produced" means production complied with the laws of the country of origin — land use, environmental protection, labour, and related rules.

To show this, the company placing the goods on the EU market must carry out due diligence and file a due diligence statement (DDS) in the EU's Information System before the goods can be sold.

As of mid-2026, EUDR is not yet in application — you have real preparation time. But the core requirements haven't been watered down: geolocation is still mandatory.

The commodities in scope

EUDR covers seven commodities and many products derived from them:

• Cattle (beef, leather, and derived products)
• Cocoa (including chocolate)
• Coffee
• Oil palm (palm oil and derivatives)
• Rubber
• Soy
• Wood (timber, furniture, paper, and derived products)

If what you supply contains or is made from any of these, you're likely in scope. If it doesn't, EUDR doesn't apply to you — so the first question is simply whether your product touches these commodities. Many food and agri suppliers are in scope through cocoa, coffee, palm oil or soy ingredients; if that's you, EUDR data will often arrive alongside the requests you already get through food-sector sustainability platforms.

Who files the DDS — probably not you

This is the part suppliers most often get wrong, so let's be clear about it.

Only the first company placing the product on the EU market submits the formal due diligence statement. Companies further down the chain don't file their own full DDS — they reference the statement already submitted upstream. So if you're a non-EU supplier selling to an EU importer, or an EU supplier selling goods that someone else first imported, the formal filing is usually your customer's job, not yours.

What is your job: providing the information your customer needs to file. They can't complete their DDS without knowing where your commodity was produced and whether it's deforestation-free and legal — so they will cascade those questions down to you. Expect them to arrive as supplier questionnaires or data requests, much like other customer ESG data requests, and increasingly written into contracts and supplier codes of conduct.

There's one meaningful simplification: micro and small primary operators in low-risk countries can submit a single simplified declaration instead of running the full repeating due diligence process. If you're a small grower or primary producer, confirm whether this applies to you — it materially changes the workload.

The heart of it: plot-level geolocation

The single most important thing EUDR requires — and the thing your customer most needs from you — is geolocation data: the coordinates of the plot(s) of land where the commodity was produced (and, for cattle, the establishments where the animals were kept). Plot-level geolocation is mandatory. It's what allows the deforestation-free claim to be checked against satellite imagery.

For a supplier, that means you must be able to trace your commodity back to where it was grown or raised, and pass those coordinates down the chain. For many suppliers this is the hard part — it requires knowing your own upstream sources, not just your immediate supplier. It's also the one task worth starting today regardless of how the timeline settles, because collecting coordinates from upstream growers is slow.

What your customer will ask you for

Depending on your position in the chain, expect requests for:

• Geolocation coordinates of the production plots or establishments.
• Deforestation-free assurance — confirmation (and supporting evidence) that the land wasn't deforested after 31 December 2020.
• Evidence of legal production — documentation that production complied with the origin country's laws.
• Traceability records linking the specific goods or batches to their origin.
• DDS reference numbers, where a statement has already been filed upstream, so your customer can reference it rather than duplicate it.

The timeline as it stands (mid-2026)

In December 2025, the European Parliament adopted changes postponing and simplifying EUDR. The application dates are now staggered by company size:

• Large and medium operators and traders: obligations apply from 30 December 2026.
• Micro and small enterprises (fewer than 50 employees and under €10M turnover for in-scope products): from 30 June 2027.

A few other practical points from the current state of implementation:

• The EU's Information System — where due diligence statements are filed — is being upgraded and is planned to reopen in June 2026, with support for simplified declarations and grouping of DDS submissions.
• Country benchmarking determines how intensively authorities check: inspection rates are set at 1% of operators for low-risk countries, 3% for standard risk, and 9% for high-risk countries. Where your commodity originates affects how much scrutiny to expect.

The timeline has now moved twice, and it could move again. Plan against the current dates — but don't build your preparation on the assumption of another delay.

How to prepare

1. Check whether you're in scope — does your product contain or derive from one of the seven commodities?
2. Map your origin — trace your commodity back to the production plots and start gathering geolocation data now. Upstream tracing is the slowest step.
3. Collect legality evidence — documentation that production complied with the origin country's laws.
4. Organise traceability — link batches to origins so you can answer a customer request quickly instead of reconstructing it under deadline pressure.
5. Confirm your company size category — large/medium versus micro/small changes both your deadline and, for small primary operators in low-risk countries, the process itself.
6. Ask your EU customer what format they want — they're the ones filing the DDS, and aligning early beats reformatting later.

What not to do

• Don't assume it doesn't apply because you're small. Small enterprises get a later date and, in some cases, a lighter process — but in-scope small suppliers still have obligations, and your EU customer needs your data regardless of your size.
• Don't guess coordinates. Geolocation is checked against satellite data; approximate or invented plots defeat the purpose and create real risk for you and your customer.
• Don't file paperwork that isn't yours to file. If you're not the first company placing the product on the EU market, your job is supplying data, not submitting the formal DDS.
• Don't rely on old deadlines — in either direction. Some older guides still cite 2024 or 2025 dates; others assume indefinite delay. Verify the current dates for your category on the Commission's page.

The bottom line

EUDR is about proving your commodity is deforestation-free and legally produced — and the practical core for suppliers is plot-level geolocation, traced back to origin and passed to your EU customer, who usually files the actual due diligence statement. The deadlines have moved to 30 December 2026 (large and medium companies) and 30 June 2027 (micro and small), which buys time for the slowest task: upstream tracing. Use it. And if your customers are also asking about carbon border rules, that's a separate regulation — see our CBAM guide for suppliers.