Article
EUDR 101: Everything you need to know about compliance
By Caoilinn O’kelly
October 26, 2026
Key takeaways
The EUDR applies from 30 December 2026. Micro and small operators established by 31 December 2024 have until 30 June 2027, and newly added products are covered from 30 December 2027.
Only operators carry out due diligence and submit DDSs in TRACES, while downstream operators and traders keep supplier and customer records.
The first downstream operator or trader must also collect DDS reference numbers from its suppliers and keep them for at least five years.
Country risk levels (low, standard or high) determine whether operators can use simplified due diligence and how often authorities carry out checks.
EUDR 101: Everything you need to know about compliance
The EU Deforestation Regulation (EUDR) applies from 30 December 2026. It affects companies across food, agriculture and consumer goods supply chains, whether they import, process or sell the products it covers. This article answers the most common questions about the EUDR: what it is, who it applies to, when it takes effect and how to prepare.
What is the EUDR?
The EUDR (Regulation (EU) 2023/1115) requires certain commodities and products made from them to meet three conditions before they can be placed on the EU market or exported:
Deforestation-free: not produced on land deforested after 31 December 2020.
Legally produced: produced in line with the laws of the country of production.
Covered by a due diligence statement (DDS) or, where allowed, a simplified declaration.
Why was the EUDR introduced?
The EUDR aims to reduce the EU's contribution to global deforestation and forest degradation. The main driver of deforestation is the expansion of agricultural land for commodities such as cocoa, coffee, soya and palm oil. The EUDR replaces the EU Timber Regulation (EUTR), which is repealed from 30 December 2026, and covers far more commodities.
How is the EUDR different from the CSDDD?
The Corporate Sustainability Due Diligence Directive (CSDDD) sets a broad, company-wide due diligence framework covering human rights and environmental impacts. The EUDR is product-specific. It applies to particular commodities and requires proof, product by product, that they are deforestation-free and legally produced.
When does the EUDR apply?
Date | What applies |
30 December 2026 | The EUDR applies to most companies. |
30 June 2027 | The EUDR applies to micro and small operators established by 31 December 2024. |
30 December 2027 | The EUDR applies to products newly added to the scope in 2026, such as soluble coffee. |
The original date was 30 December 2024. It was postponed twice: by Regulation (EU) 2024/3234 and by Regulation (EU) 2025/2650, which also simplified the obligations. See The Ins and Outs of the EUDR for the full timeline.
Which products does the EUDR apply to?
The EUDR covers seven commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood. It also covers derived products listed in Annex I, such as chocolate, furniture and paper.
Delegated Regulation (EU) 2026/2102 recently changed the scope:
Added from 30 December 2027: soluble coffee, palm oil oleochemical derivatives and frozen cattle tongues.
Removed: leather, among other products.
The full product list is in Annex I of the regulation.
Who is responsible for EUDR compliance?
There are three roles:
Operators place relevant products on the EU market for the first time or export them. They carry out due diligence and submit a DDS in TRACES.
Downstream operators place on the market or export products made from products already covered by a DDS. They don't submit a DDS.
Traders make products available that are already on the EU market. They don't submit a DDS either.
Downstream operators and traders of all sizes must keep supplier and customer details for at least five years. The first downstream operator or trader, meaning the company that buys directly from an operator, must also collect the DDS reference numbers from its suppliers. Non-SME downstream operators and traders must register in TRACES.
Not sure which role applies to you? Contact us for more information.
Do non-EU producers need to comply?
The legal obligations sit with whoever places the product on the EU market, usually the EU importer. Non-EU producers are affected in practice, because operators need them to provide geolocation data and evidence of legal production. Without that data, the product cannot be placed on the EU market.
What happens if you don't comply?
Penalties are set by each Member State, but they must include:
Fines, where the maximum must be at least 4% of the company's annual EU-wide turnover
Confiscation of products and revenues
Temporary exclusion from public procurement and public funding for up to 12 months
A temporary ban on placing products on the market
Loss of the right to use simplified due diligence
Non-compliance can also damage your reputation and your relationships with customers.
What does due diligence involve?
Due diligence is an obligation for operators. It has three steps.
1. Information gathering. This covers the product, quantity, suppliers, country of production, the geolocation of every production plot, and evidence that the product is deforestation-free and legally produced.
2. Risk assessment. Before placing a product on the market, operators assess the risk that it is non-compliant. Country risk is one factor, alongside others such as the presence of forests, Indigenous peoples' rights and corruption.
3. Risk mitigation. If the risk is more than negligible, operators must reduce it before placing the product on the market (Article 11). They can do this by requesting additional information or documents, or by commissioning independent surveys or audits.
The operator then submits the DDS in TRACES. The due diligence system must be reviewed at least once a year.
What risk level is the country you are sourcing from?
The European Commission classifies countries as low, standard or high risk. The classification determines the minimum share of companies that authorities must check each year.
Risk level | Minimum annual checks | Examples |
Low | At least 1% of relevant companies | EU Member States, USA, Canada, China |
Standard | At least 3% of relevant companies | Brazil, Indonesia |
High | At least 9% of relevant companies and 9% of product quantity | Belarus, Myanmar, North Korea, Russia |
Operators sourcing only from low-risk countries can apply simplified due diligence. They don't need to do the risk assessment and mitigation steps unless they receive information that points to a risk. The Commission reviews the list regularly, so always check the latest country classification.
How does the EUDR affect smallholders and producers?
Many suppliers, particularly smallholders outside the EU, are not yet familiar with the EUDR requirements. Operators depend on them for geolocation data, so clear communication and support are essential to get consistent, reliable data from the start.
How can you prepare?
Check your scope: confirm which of your products are in scope, including the 2026 changes.
Determine your role: for each product, work out whether you are an operator, downstream operator or trader.
Agree on data sharing: agree with your suppliers how they will share DDS reference numbers or geolocation data.
Set up record-keeping: make sure your systems can store and retrieve the records your role requires for at least five years.
Use digital tools: a digital platform helps you standardise how this data is collected and stored, instead of chasing documents by email.
How Simvia supports first downstream operators
If you buy relevant products directly from an operator, you are a First Downstream Operator. Simvia gives you one place to receive, link and store DDS reference numbers:
Tag the products and suppliers that fall under the EUDR.
Map the supply chain of each product.
Request DDS information from suppliers based on rules you set.
Receive DDS documents and reference numbers in a simple way from suppliers. Simvia extracts the key details from shared documents using AI.
Keep audit-ready records for five years or more, with an Excel export so you can respond quickly to authorities and retailers.
Want to know how Simvia can help you prepare for the EUDR?
