If you supply wood, coffee, cocoa, rubber, palm oil, soy, or cattle products — or goods made from them — a customer has probably asked about EUDR. What they need is specific: proof of where the commodity was produced and that the land was not deforested after 31 December 2020.
Before collecting anything, establish whether your product is in scope, who files the statement, and which deadline applies to your company size.
| First question | Short answer |
|---|---|
| Does it apply to me? | Only if your product contains or derives from cattle, cocoa, coffee, oil palm, rubber, soy, or wood. |
| Do I file the due diligence statement? | Usually not. The operator first placing the product on the EU market files. You supply the data. |
| What is the one thing they need? | Plot-level geolocation of where the commodity was grown or raised. |
| When does it apply? | Large and medium companies: 30 December 2026. Micro and small: 30 June 2027. |
| Could the dates move again? | They have moved twice. Plan against the current dates and check the Commission page for anything deadline-critical. |
Regulation details and links checked 19 July 2026. EUDR's application has been postponed twice, most recently in December 2025. For deadline-critical decisions use the European Commission's implementation page rather than any article, including this one.
What EUDR is
The EU Deforestation Regulation 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 was not deforested or degraded after 31 December 2020. Legally produced means production complied with the laws of the country of origin: land use, environmental protection, labor, and related rules.
To show this, the company placing the goods on the EU market carries out due diligence and files 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. The core requirements have not been reduced: geolocation remains mandatory.
Commodities in scope
Seven commodities and many products derived from them:
- Cattle — beef, leather, derived products
- Cocoa — including chocolate
- Coffee
- Oil palm — palm oil and derivatives
- Rubber
- Soy
- Wood — timber, furniture, paper, derived products
If what you supply contains or is made from any of these, you are likely in scope. If not, EUDR does not apply to you. Many food and agricultural suppliers are in scope through cocoa, coffee, palm oil, or soy ingredients; for them, EUDR data requests often arrive alongside requests from food-sector sustainability platforms.
Who files the DDS
The formal due diligence statement is usually filed by the operator that first places the product on the EU market. Companies further down the chain typically do not file their own full DDS; they reference the statement already submitted upstream. Downstream operators and traders still carry duties of their own: registration, record-keeping, and passing on DDS reference numbers.
A non-EU supplier selling to an EU importer therefore normally provides the data for the customer's statement rather than filing one.
The supplier's job is the information the customer needs to file. The customer cannot complete a DDS without knowing where the commodity was produced and whether it is deforestation-free and legal, so those questions cascade down as supplier questionnaires and data requests — the same route as other customer ESG data requests — and increasingly into contracts and supplier codes of conduct.
One 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. A small grower or primary producer should confirm whether this applies; it changes the workload materially.
Plot-level geolocation
The single most important requirement, and the thing your customer most needs from you, is geolocation data: the coordinates of the plot or plots of land where the commodity was produced, and for cattle the establishments where the animals were kept. Plot-level geolocation is mandatory. It is what allows the deforestation-free claim to be checked against satellite imagery.
For a supplier this means tracing the commodity back to where it was grown or raised and passing those coordinates down the chain. For many suppliers this is the hard part: it requires knowing upstream sources, not only the immediate supplier. It is the one task to start regardless of how the timeline settles, because collecting coordinates from upstream growers is slow.
What the customer will ask for
Depending on your position in the chain:
- Geolocation coordinates of the production plots or establishments
- Deforestation-free assurance — confirmation and supporting evidence that the land was not deforested after 31 December 2020
- Evidence of legal production — documentation that production complied with the origin country's laws
- Traceability records linking specific goods or batches to their origin
- DDS reference numbers where a statement has already been filed upstream, so the customer can reference it
The timeline
In December 2025 the European Parliament adopted changes postponing and simplifying EUDR. 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.
Other points from the current state of implementation:
- The EU Information System, where due diligence statements are filed, is being upgraded and was planned to reopen in June 2026, with support for simplified declarations and grouped DDS submissions.
- Country benchmarking sets inspection rates: 1% of operators for low-risk countries, 3% for standard risk, 9% for high-risk countries. Where the commodity originates determines how much scrutiny to expect.
The timeline has moved twice and could move again. Plan against the current dates. Do not build preparation on the assumption of another delay.
How to prepare
- Check scope. Does the product contain or derive from one of the seven commodities?
- Map origin. Trace the commodity back to the production plots and start gathering geolocation data. Upstream tracing is the slowest step.
- Collect legality evidence. Documentation that production complied with the origin country's laws.
- Organize traceability. Link batches to origins so a customer request can be answered from records.
- Confirm your company size category. Large or medium versus micro or small changes the deadline and, for small primary operators in low-risk countries, the process.
- Ask the EU customer what format they want. They file the DDS. Aligning early avoids reformatting later.
What not to do
- Do not assume it does not apply because you are small. Small enterprises get a later date and sometimes a lighter process, but in-scope small suppliers still have obligations, and the EU customer needs your data regardless of your size.
- Do not guess coordinates. Geolocation is checked against satellite data. Approximate or invented plots defeat the purpose and create risk for you and your customer.
- Do not file paperwork that is not yours to file. If you are not the operator first placing the product on the EU market, your job is usually supplying data.
- Do not rely on old deadlines in either direction. Older guides 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 the commodity is deforestation-free and legally produced. The practical core for suppliers is plot-level geolocation, traced to origin and passed to the EU customer, who usually files the due diligence statement. The deadlines are 30 December 2026 for large and medium companies and 30 June 2027 for micro and small, which leaves time for the slowest task: upstream tracing. If customers are also asking about carbon border rules, that is a separate regulation — see the CBAM guide for suppliers.
Official References
- European Commission — Deforestation Regulation implementation
- European Parliament — December 2025 changes to EUDR