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 was published in the Official Journal of the EU on 9 June 2023.
It was amended by Regulation (EU) 2025/2650 of 19 December 2025 as regards its date of entry in application and certain implementing rules.
Presentation
The Regulation prohibits the placing on the market or export from the European market of products that have contributed to deforestation or forest degradation after 31 December 2020. The Regulation will enter into force on 30 December 2026 (with a deadline of 30 June 2027 for micro and small enterprises).
The scope of the text covers seven commodities: coffee, cocoa, rubber, oil palm, soya, cattle and wood, as well as certain derived products (e.g.: wood charcoal, cocoa butter). The products concerned are listed exhaustively in Annex 1 to the EUDR, based on their customs nomenclature.
Deforestation refers to the conversion of “forests”, as defined by the Food and Agriculture Organization of the United Nations (FAO), to agricultural use. Forest degradation is defined on the basis of different criteria for structural changes in forest cover.
The scheme proposed by the Regulation sets out traceability and transparency obligations in order to make the sustainability of supply chains a new standard.
It requires economic operators to ensure that the products they export or place on the EU market carry no or negligible risk of having caused deforestation.
Specific provisions are laid down depending on:
- The role of the company in the value chain;
- The size of the company;
- The classification of the countries of origin of the products, based on their level of risk (low, standard, high).
All available resources are available at the end of this article.
What are the different roles in the value chain?
Article 2
A company that makes available on the market products covered by the EUDR may, depending on its place in the value chain, be considered as an operator, downstream operator or trader within the meaning of the EUDR.
1. Operator, including the "primary micro or small operator"
An operator is a natural or legal person who, in the course of a commercial activity, places relevant products on the market or exports them for the first time.
Example: An importer of cocoa beans or an importer of parquet flooring.
A subcategory of operator is that of “micro or small primary operators”, corresponding to the following three cumulative criteria:
- micro and small enterprises*, or natural persons;
- established in a low-risk country;
- producing and placing on the market their own products.
Example: a cattle farmer or a forestry operator, who fulfils each of the three criteria listed above.
*Small and micro-enterprises are defined in Article 3(1) or (2) of Directive 2013/24/EU.
2. Downstream operator
A downstream operator is a natural or legal person who, in the course of a commercial activity, places on the market products covered by the EUDR that have already been subject to a due diligence statement or a simplified declaration when first placed on the market.
Example: a chocolate manufacturer that purchases cocoa beans from an importer and processes those beans into chocolate, or a sawmill that purchases wood from a forest operator.
3. Trader
A trader is a natural or legal 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.
Example: A retailer.
What are the main obligations of companies?
Articles 4, 4a, 5, 8 to 13
The obligations of companies under EUDR depend on their role in the value chain.
Operators shall exercise due diligence before importing, exporting or placing on the Union market for the first time the products listed in Annex 1 to the EUDR. They shall carry out a due diligence statement in the dedicated European Information System (TRACES) before each placing on the market. They transmit to their first customer (downstream operator or trader) the due diligence declaration number corresponding to the products sold as well as certain information about their company (name, registered trade name or registered trade mark, postal address, e-mail address and, where applicable, internet address).
Micro and small primary operators have the possibility to make a single simplified due diligence declaration, containing the information listed in Annex 3 of the EUDR.
Operators shall establish and maintain a due diligence system corresponding to a framework of procedures and measures ensuring that the products they place on the market or export comply with Article 3.
The first downstream operators or traders shall keep the information transmitted to them by the first placer on the EU market selling products covered by the EUDR for a period of 5 years (including the reference number of the due diligence statement). They transmit to their client following a series of information about their company (name, company name or registered trademark, postal address, e-mail address and, where applicable, internet address). They are not required to provide their following customers with the reference number of the due diligence statement number.
All companies (operators, downstream operators, and traders) that trade in products covered by EUDR and that are not SME’s must register in the European Commission’s information system (TRACES).
What is due diligence?
Articles 8, 9, 10 and 11
Before placing the products in question on the market or before exporting them, operators shall exercise due diligence with regard to all the products in question.
Due diligence consists of three items: information gathering, risk assessment measures and risk mitigation measures.
What is simplified due diligence?
Article 13
Operators can perform simplified due diligence (no risk assessment or risk mitigation) if the products in question come from countries or parts of countries classified as low risk by the European Commission. In this case, operators will have to make available to the control authorities, upon request, the relevant documents proving that there is a negligible risk of circumvention of this Regulation or of mixing with products of unknown origin or originating in countries or parts thereof posing a high or standard risk.
What is a due diligence system?
Article 12
Companies subject to the EUDR will have to establish a due diligence system that corresponds to the framework of procedures and measures ensuring the legality and non-deforestation of products placed on the market or exported.
Operators first placing on the market must collect information attesting to the compliance of products with the zero deforestation requirement and legality (Article 9). All this information must be kept for 5 years.
Operators will need to review their due diligence system at least once a year.
Operators that do not fall under the categories of VSE/SME will have to publish an annual report on their due diligence system, presenting the steps taken to meet their due diligence obligations.
What is the due diligence statement?
Articles 3, 4, 4a, 33 and Annexes 2 and 3
Before each first placing on the EU market, import, or export, operators will have to complete a due diligence statement in the information system of the European Commission: TRACES that will centralise all of these declarations.
The elements to be included in this declaration are listed in Annex 2 of the EUDR.
The operator will receive a due diligence statement (DDS) reference number, which it must transmit to the first operator or trader downstream of the value chain. This first downstream operator or downstream trader is required to keep this DDR number.
Micro and small primary operators have the possibility to make a single simplified due diligence declaration, containing the information listed in Annex 3 of the EUDR.
Find out more about the EUDR information system
What is the role of the authorised representative?
Articles 6 and 2.22
An operator may appoint an authorised representative to carry out the due diligence statement on its behalf. Several conditions must be met: a mandate must be drawn up between the operator and the designated body, and the authorised representative must be based in the EU.
The assignment of an authorised representative role in the TRACES information system provides access to operator prerogatives in the access and management of due diligence statements. Where an authorised representative is used, the operator or trader remains fully responsible for the compliance of the product covered by the due diligence statement.
It is also possible for a company to authorise the next operator or trader in the supply chain to act as authorised representative, provided that the mandated organisation is not a natural person or a micro-enterprise (Article 6.3).
Finally, the role of authorised representative within the meaning of the EUDR as presented above should not be confused with that of customs representative or registered customs representative. A registered customs representative acts on behalf of an economic operator in order to carry out, the formalities laid down by the customs legislation with the customs authorities, in particular the customs declaration. As such, the customs representative must, for the products listed in Annex 1 to the EUDR, enter in the customs declaration the dedicated document code followed by the due diligence declaration number or a specific tariff provision (see below: “Are there any customs formalities related to EUDR?”).
What is the timetable for the entry into application and review of the Regulation?
Articles 34 and 38 as amended
The EUDR enters into force on 30 December 2026 with a deadline of six months for micro and small enterprises for which it shall apply from 30 June 2027.
The Regulation will be reviewed by 30 June 2030 and at least every 5 years thereafter.
What is country benchmarking?
Article 29 as amended
The European Commission has classified countries or parts of countries according to three risk categories (high, standard, low).
This list was published by the European Commission on 22 April 2025 and may be updated when the Commission deems it necessary.
This ranking is based on an assessment based mainly on the following criteria:
- the rate of deforestation and forest degradation;
- the rate of expansion of agricultural land for the commodities in question;
- trends in the production of the relevant commodities and products.
Other criteria taken into account are listed in Article 29.4 of the EUDR.
The European Commission has published
the methodology underlying this ranking.
What checks will be carried out?
Articles 16 to 19
Checks will be carried out by the designated authorities within each country. The annual checks carried out must cover at least:
- 1% of operators whose products come from low-risk countries or parts thereof
- 3% of operators whose products come from countries or parts of countries with standard risk
- 9% of operators whose products come from high-risk countries or parts of countries as well as 9% of the quantity of each of the products
Are there any customs formalities related to EUDR?
Yes. However, it is not a question of producing a specific document. The due diligence statement reference number must be made available to the customs authorities before the product is released for free circulation or exported.
In order to determine whether their products are covered by the EUDR, companies should consult the list in Annex 1 to the Regulation and identify the customs nomenclature on the basis of the official classification or by consulting their customs referrer. In case of uncertainty, they may request an EU Binding Tariff Information (EBTI), which allows the customs administration to confirm the tariff classification of a product.
Specifically: in order to clear in customs a product listed in Annex 1 to the EUDR, the reference number of the due diligence statement (DDS) must be added in the box reserved for the documents in the customs declaration, preceded by the document code corresponding to the EUDR:
- Code C716: applicable for any goods subject to EUDR
A customs nomenclature may be listed in Annex 1 of the EUDR without the product being subject to the obligations of the Regulation. In these situations, the relevant special provision code must be indicated in the box reserved for the documents in the customs declaration:
- Y129: where the product has a customs code listed in Annex 1 but not covered by the EUDR
- Y132: where the product was manufactured before 29 June 2023
- Y133: where the product is derived from recycled materials
- Y141: where the product is imported or exported by a micro or small enterprise before 30 June 2027
- Y142: in the case of a product transiting through customs outside a commercial activity. For the notion of commercial activity, it is possible to refer to question 3.2 of the EUDR FAQ.
Who is the competent authority in France?
Article 14
A joint competent authority was designated in France composed of:
- Ministry of Ecological Transition and Territorial Cohesion
- Ministry of Agriculture and Food Sovereignty
Resources
EU Commission Impact Assessment accompanying the EUDPR - in English (November 2021)
Framing documents
Guidance document of the European Commission detailing certain regulatory obligations (May 2026)
Strategic Framework for International Cooperation published in October 2024, highlighting the principles and modalities for international action with the aim of accompanying and supporting the fight against deforestation in third countries in the context of the EUDR.
The European Commission has also published
sector specific scenarios and infographics
(May 2026)
On page 8 of this document, a table summarizes the obligations of companies according to their size and status ("operator" or "trader").
Questions and answers
EU Commission Frequently Asked Questions on EUDR (May 2026)
TRACES Information System
The TRACES information system is the digital interface where companies submit and manage their due diligence statements.
It has been open again since 30/06/2026, accessible at the following link: https://eudr.webcloud.ec.europa.eu/tracesnt/login
Several resources are made available to companies by the European Commission.
A test site (https://acceptance.eudr.webcloud.ec.europa.eu/tracesnt/login) was also made available
Other publications
EU Deforestation Regulation: an opportunity for smallholders by the European Commission (November 2023)
Biodiversity: Deforestation-free products on the EU market by the European Commission (November 2021)
Find out more
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