That includes processed goods like leather, chocolate, books, wooden furniture, rubber clothing, and more. It doesn\u2019t matter if the item was produced in or outside the EU. What matters is whether it ends up on the EU market or leaves it through export.<\/p>\n\n\n\n
You\u2019ll need to check if your product\u2019s HS or CN code appears in Annex I of the regulation. If it does, you\u2019re in scope. There are a few exemptions, like fully recycled materials and packaging used only for transport, but otherwise, the list is long and growing.<\/p>\n\n\n\n
Who Has to Comply?<\/h2>\n\n\n\n
There are a few categories to understand here. The main ones are:<\/p>\n\n\n\n
- \n
- Betreiber<\/strong>: Businesses that first place the product on the EU market or export it<\/li>\n\n\n\n
- H\u00e4ndler<\/strong>: Those who make the product available after it\u2019s already in the EU market<\/li>\n<\/ul>\n\n\n\n
If you\u2019re a large operator or trader, your obligations are full-scale. You must gather data, assess deforestation risk, mitigate that risk if needed, and submit a due diligence statement for every shipment.<\/p>\n\n\n\n
If you\u2019re a small or micro business, your obligations might be lighter, but you\u2019re not off the hook. You may be able to refer to a previous due diligence statement (DDS) created upstream, but only if it\u2019s valid and properly referenced.<\/p>\n\n\n\n
SME vs Non-SME Obligations (Quick Snapshot)<\/h3>\n\n\n\n
Obligation<\/strong><\/td> Non-SME Operator<\/strong><\/td> SME Operator<\/strong><\/td> Non-SME Trader<\/strong><\/td> SME Trader<\/strong><\/td><\/tr> Due diligence system<\/td> Yes<\/td> Sometimes*<\/td> Yes<\/td> No<\/td><\/tr> Submit DDS<\/td> Yes<\/td> Sometimes*<\/td> Yes<\/td> No<\/td><\/tr> Keep supply chain records<\/td> Yes<\/td> Yes<\/td> Yes<\/td> Yes<\/td><\/tr> Reference upstream DDS<\/td> Allowed<\/td> Allowed<\/td> Allowed<\/td> Allowed<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n *Only exempt if product has already been covered by a DDS from another operator.<\/p>\n\n\n\n
![\"\"](\"https:\/\/eudr.co\/wp-content\/uploads\/2025\/09\/deforestation4-1-1024x683.jpg\")
<\/figure>\n\n\n\nDeadlines: What Changed and What Still Stands<\/h2>\n\n\n\n
Originally, the regulation was set to apply from 30 December 2024. That\u2019s now been pushed back:<\/p>\n\n\n\n
- \n
- Large companies<\/strong> must comply by 30 December 2025<\/li>\n\n\n\n
- SMEs<\/strong> have until 30 June 2026<\/li>\n\n\n\n
- Exception<\/strong>: If SMEs are selling products from large companies, they still need to comply by 30 December 2025<\/li>\n<\/ul>\n\n\n\n
If you\u2019re in the wood or forestry sector, note that EUTR will officially be repealed on 30 December 2025, and all wood products must fall under EUDR rules from that date.<\/p>\n\n\n\n
The Core of Compliance: Due Diligence System<\/h2>\n\n\n\n
Here\u2019s where the rubber meets the road. Your due diligence system is not a single report or an annual check-in. It\u2019s an ongoing, structured process that includes:<\/p>\n\n\n\n
1. Information Collection<\/h3>\n\n\n\n
You need to collect specific data for every product batch. This includes:<\/p>\n\n\n\n
- \n
- Product description and quantity<\/li>\n\n\n\n
- Country of production<\/li>\n\n\n\n
- Name and address of supplier and buyer<\/li>\n\n\n\n
- Date or production range<\/li>\n\n\n\n
- Geolocation coordinates of the land plot where the commodity was grown or raised<\/li>\n<\/ul>\n\n\n\n
That last point is a big deal. The location must be mapped to 1 second of latitude and longitude (roughly a 31m x 31m square). For larger plots, polygon mapping is required.<\/p>\n\n\n\n
2. Risk Assessment<\/h3>\n\n\n\n
With the data in hand, you must assess the risk that the product came from land deforested or degraded after 31 December 2020. You\u2019ll need to consider:<\/p>\n\n\n\n
- \n
- Forest presence in the area<\/li>\n\n\n\n
- Rate of deforestation in the region<\/li>\n\n\n\n
- Legal compliance of producers<\/li>\n\n\n\n
- Whether indigenous land rights were respected<\/li>\n\n\n\n
- Reliability of documents and certifications<\/li>\n\n\n\n
- Complexity and transparency of the supply chain<\/li>\n<\/ul>\n\n\n\n
If your risk assessment finds no risk, you can move forward. If there\u2019s any doubt, you must mitigate that risk before placing the product on the market.<\/p>\n\n\n\n
3. Risk Mitigation<\/h3>\n\n\n\n
When risk is non-negligible, you\u2019ll need to act. That might mean:<\/p>\n\n\n\n
- \n
- Requesting more documentation<\/li>\n\n\n\n
- Performing third-party audits<\/li>\n\n\n\n
- Delaying purchase or shipment until verification<\/li>\n\n\n\n
- Adding contractual obligations or training for suppliers<\/li>\n<\/ul>\n\n\n\n
And remember, even if your product comes from a low-risk country, you still have to meet the information gathering requirements. You just don\u2019t need to go through full risk assessment and mitigation.<\/p>\n\n\n\n
Country Benchmarking and Risk Levels<\/h2>\n\n\n\n
The EU published the first country classification system in May 2025, though it was rejected in July 2025 and is undergoing revision. Countries will be ranked as:<\/p>\n\n\n\n
- \n
- Geringes Risiko<\/strong>: Minimal checks needed, simplified due diligence applies<\/li>\n\n\n\n
- Standard-Risiko<\/strong>: Full due diligence required<\/li>\n\n\n\n
- Hohes Risiko<\/strong>: Full due diligence plus enhanced scrutiny by EU authorities<\/li>\n<\/ul>\n\n\n\n
These classifications will directly affect how deep your compliance checks need to go. Some examples from the initial list include:<\/p>\n\n\n\n
- \n
- Geringes Risiko<\/strong>: USA, UK, EU states, Canada, Australia, Japan<\/li>\n\n\n\n
- Hohes Risiko<\/strong>: Russia, North Korea, Myanmar, Belarus<\/li>\n\n\n\n
- Standard-Risiko<\/strong>: Brazil and many others<\/li>\n<\/ul>\n\n\n\n
If your product pulls ingredients from multiple countries, the strictest risk level applies.<\/p>\n\n\n\n
![\"\"](\"https:\/\/eudr.co\/wp-content\/uploads\/2025\/09\/deforestation15-1-1024x576.jpg\")
<\/figure>\n\n\n\nSubmitting a Due Diligence Statement (DDS)<\/h2>\n\n\n\n
Before placing any relevant product on the market, you must submit a DDS via the EU Information System (TRACES NT). This statement needs to include:<\/p>\n\n\n\n
- \n
- Product and shipment details<\/li>\n\n\n\n
- Operator ID and contact info<\/li>\n\n\n\n
- Geolokalisierungsdaten<\/li>\n\n\n\n
- Reference numbers of related DDSs<\/li>\n\n\n\n
- Confirmation that due diligence has been carried out<\/li>\n<\/ul>\n\n\n\n
There are limits: one DDS can have up to 200 product lines, 500 lines of explanation, and a total size of 25 MB. You can include more than one country of production, but details like the scientific name of timber and country of origin will be visible.<\/p>\n\n\n\n
You can appoint an authorized representative to handle DDS submissions, but the responsibility still lies with the operator.<\/p>\n\n\n\n
The Packaging Exception (and Its Limits)<\/h2>\n\n\n\n
Packaging is mostly exempt from EUDR if it\u2019s clearly used only to protect or carry another product (e.g., boxes, pallets). However, there are exceptions:<\/p>\n\n\n\n
- \n
- Packaging sold separately is not exempt<\/li>\n\n\n\n
- Special packaging like wooden gift boxes may be subject if it contributes to the product’s identity<\/li>\n<\/ul>\n\n\n\n
So don\u2019t assume your shipping materials are off the radar. Check CN codes carefully.<\/p>\n\n\n\n
Common Misunderstandings to Avoid<\/h2>\n\n\n\n
Even companies trying to comply can get tripped up by assumptions. Here are a few things to watch for:<\/p>\n\n\n\n
- \n
- FSC certification \u2260 automatic compliance<\/strong>. Certifications can support due diligence but don\u2019t replace it.<\/li>\n\n\n\n
- Factory location is not enough<\/strong>. You need the origin of the raw material, not the processing plant.<\/li>\n\n\n\n
- One DDS per year? Not allowed.<\/strong> A new DDS must be submitted for each shipment unless it\u2019s exactly the same batch.<\/li>\n\n\n\n
- Internal transfers within a company still count<\/strong> if there\u2019s a change of ownership.<\/li>\n<\/ul>\n\n\n\n
What About Substantiated Concerns?<\/h2>\n\n\n\n
Anyone \u2013 including individuals, NGOs, or regulators \u2013 can raise a substantiated concern if they believe a product violates EUDR. That triggers an official investigation. If you\u2019ve skipped steps or relied on poor-quality data, you\u2019ll be exposed.<\/p>\n\n\n\n
Non-Compliance Consequences<\/h2>\n\n\n\n
The stakes are high. Failing to meet EUDR requirements can lead to:<\/p>\n\n\n\n
- \n
- Confiscation of goods<\/li>\n\n\n\n
- Fines up to 4% of annual EU turnover<\/li>\n\n\n\n
- Temporary bans on trading<\/li>\n\n\n\n
- Reputational damage with buyers, consumers, and investors<\/li>\n<\/ul>\n\n\n\n
And remember, enforcement levels differ by country risk. Audits will cover:<\/p>\n\n\n\n
- \n
- 9% of shipments from high-risk countries<\/li>\n\n\n\n
- 3% from standard-risk<\/li>\n\n\n\n
- 1% from low-risk<\/li>\n<\/ul>\n\n\n\n
Steps You Can Take Right Now<\/h2>\n\n\n\n
If you\u2019re not sure where to start, here\u2019s a basic to-do list:<\/p>\n\n\n\n
- \n
- Review your product list and check Annex I<\/li>\n\n\n\n
- Identify all raw materials and their country of origin<\/li>\n\n\n\n
- Start collecting geolocation data from suppliers<\/li>\n\n\n\n
- Set up a basic due diligence system with documentation controls<\/li>\n\n\n\n
- Talk to suppliers about traceability, training, and risk policies<\/li>\n\n\n\n
- Monitor updates to the EU country classification list<\/li>\n\n\n\n
- Register for access to TRACES NT and learn how DDS submission works<\/li>\n<\/ul>\n\n\n\n
- Factory location is not enough<\/strong>. You need the origin of the raw material, not the processing plant.<\/li>\n\n\n\n
- FSC certification \u2260 automatic compliance<\/strong>. Certifications can support due diligence but don\u2019t replace it.<\/li>\n\n\n\n
- Hohes Risiko<\/strong>: Russia, North Korea, Myanmar, Belarus<\/li>\n\n\n\n
- Standard-Risiko<\/strong>: Full due diligence required<\/li>\n\n\n\n
- Geringes Risiko<\/strong>: Minimal checks needed, simplified due diligence applies<\/li>\n\n\n\n
- SMEs<\/strong> have until 30 June 2026<\/li>\n\n\n\n
- H\u00e4ndler<\/strong>: Those who make the product available after it\u2019s already in the EU market<\/li>\n<\/ul>\n\n\n\n
![\"\"](\"https:\/\/eudr.co\/wp-content\/uploads\/2025\/06\/eudr.png\")
<\/figure>\n\n\n\n