The EU deforestation rules (EUDR), answered

The dates come from Article 38 as replaced by Regulation (EU) 2025/2650. Read them as three separate questions:

• Which articles start? Articles 3 to 13, 16 to 24, 26, 31 and 32. That is the prohibition, the due diligence, the statements, the checks and the customs chapter; in practice, all of it.
• Are you small, and since when? The later date is not for anyone who happens to be small in 2027. You must have been established as a natural person or as a micro or small undertaking within the meaning of Article 3(1) or 3(2) of Directive 2013/34/EU by 31 December 2024.
• What are you shipping? A small operator dealing in timber and timber products that were covered by the Annex to Regulation (EU) No 995/2010 does not get the extra six months for those goods.

Two postponements in three years is a pattern, not a promise. Plan for December 2026 and treat any further delay as a windfall; the work that takes longest, collecting geolocation from every supplier, is the work you cannot start late.

Three things about the list that decide most cases:

• Derived products are in. Leather, chocolate, palm-based fatty acids and glycerol, tyres and rubber gloves, furniture, plywood, pulp and paper. The commodity you never bought is in your product.
• “ex” means part of the heading. An entry such as ex 4011 covers only the goods of that heading that contain or were made using the relevant commodity. Your classification alone does not settle it; the material does the rest.
• The list moves. The Commission can amend Annex I by delegated act, and did: Regulation (EU) 2025/2650 deleted the printed-matter line (ex 49). Books and newspapers of paper are no longer a relevant product; the pulp and paper of chapters 47 and 48 they are printed on still are.

Recycled material is treated differently: goods produced entirely from material that has completed its lifecycle and would otherwise be discarded as waste are outside the regulation, except for by-products of a manufacturing process where that process involved material that was not waste.

The three roles were rewritten in December 2025, and the rewrite is the substance of the simplification. What each one owes:

• Operator. Exercises due diligence, submits a due diligence statement before placing on the market or exporting, keeps the records for five years, and carries responsibility for compliance with Article 3.
• Downstream operator. Does not submit a statement. Must hold, and keep for five years, the identity and contact details of who supplied the goods and, where the supplier is an operator, the reference numbers or declaration identifiers; plus who they supplied on to. If they are not an SME they must also register in the information system before placing goods on the market.
• Trader. Same information duty as a downstream operator, and the same registration duty when not an SME.

Two traps. First, importing into the Union makes you an operator, whatever you call yourself internally: the first making available on the Union market is the trigger. Second, buying inside the Union from an operator who has already filed does not automatically make you a downstream operator; that only holds where every relevant product you use is itself covered by a statement or a simplified declaration.

The second condition is the one importers underestimate. “Legal in the country of production” is not a general impression of legality; it reaches land use rights, environmental and forest law, third parties' rights, labour rights, human rights protected under international law, the principle of free, prior and informed consent, and tax, anti-corruption, trade and customs rules. You are expected to hold evidence on each of those that is relevant to your chain.

The first condition, deforestation-free, has a fixed date and no grandfathering: the commodity must have been produced on land that has not been subject to deforestation after 31 December 2020, and wood must have been harvested without inducing forest degradation after that date. A plot cleared in 2021 is disqualified, and everything from that plot with it.

This is the requirement that takes months, because it is not yours to produce. What to ask for, in the order suppliers can answer it:

• Which plots fed this shipment. Not the whole estate; the plots behind the lot you bought. Mixing lots from many smallholders means many plots, and every one of them travels with the goods.
• Point or polygon. Under four hectares a point is enough. Over four hectares it must be a polygon, and a point supplied for a large plot is a defective statement, not a rounding.
• The production date or time range. The coordinates alone do not show that the harvest predates nothing; the date is part of the requirement.
• Who is upstream and downstream. Name, postal address and email address of whoever supplied you and of whoever you supplied.

Any deforestation or forest degradation on a given plot disqualifies every commodity and product from that plot automatically. That is why suppliers resist handing over coordinates: it is checkable, from satellite, by anyone, for ever.

One relief was added in December 2025: a micro or small primary operator may give the postal address of the plots or of the establishment instead of the geolocation. That relief belongs to the producer at the start of the chain, not to you as importer.

The mechanics, in the order they happen:

• Register in the information system. The system is the one set up under Article 33 and is run on the TRACES platform. Non-SME downstream operators and non-SME traders must register there too, even though they file no statement.
• Submit the statement. It carries the information in Annex II: your name and address and, for goods entering or leaving the Union, your EORI number; the HS code, description and quantity; the country of production and the geolocation of all plots; the reference numbers of any statements you rely on; the declaration itself; and a signature.
• Get the reference number to customs. It has to be available to the customs authorities before release for free circulation or export. In practice that means the number goes into your customs declaration, so your broker needs it before the vessel arrives, not after.
• Keep the record for five years. Not the goods, the statement.

Submitting the statement is the moment you assume responsibility for the product's compliance with Article 3. It is a legal act, not an upload.

Which one applies to you depends on what you are, not on how you feel about your size:

• Later date. Natural persons and micro or small undertakings under Directive 2013/34/EU, established as such by 31 December 2024: 30 June 2027 instead of 30 December 2026, except for goods covered by the old timber regulation.
• Simplified regime. A micro or small primary operator, meaning one established in a country classified as low risk who places on the market what it grew, harvested, obtained or raised itself, submits a one-time simplified declaration in the information system and receives a declaration identifier. Risk assessment and risk mitigation do not apply to them, and postal addresses may replace geolocation.
• No duplicate due diligence. An SME operator does not have to exercise due diligence again on parts of a product that were already covered by a statement; it gives the competent authority the reference number on request.

None of the three is available to an EU importer buying from a third country. The simplified regime in particular sits at the production end of the chain, not the import end; a European trading company is not a micro or small primary operator however small it is.

The three tiers come from Article 29 and are set by implementing act. As adopted on 22 May 2025 the picture is lopsided: 140 countries low risk, four high risk (Belarus, the Democratic People's Republic of Korea, Myanmar and the Russian Federation), and every country not named is standard risk by default. That default is where most tropical origins sit.

The tier changes three things:

• Your workload. Low risk allows the simplified due diligence of Article 13; standard and high risk do not.
• Your odds of being checked. Member states must check at least 1 per cent of operators and non-SME downstream operators and traders for low-risk origin, 3 per cent for standard risk, and 9 per cent for high risk, plus 9 per cent of the quantity of each relevant product from high-risk origin.
• Nothing about the cut-off date. A low-risk country does not make a plot cleared in 2021 acceptable.

The list is reviewed and updated, so check the current version before you build a process on it. A country moving from low to standard is a change in your obligations, not in your paperwork.

What that means for a shipment, practically:

• The number travels with the declaration. Unless it comes through the electronic interface between the customs systems and the information system, whoever lodges the declaration supplies it.
• Customs check status, not substance. They look up the status the competent authority gave the statement. The substantive check is the competent authority's, on a risk basis.
• Suspension is normal, not exceptional. A flagged statement stops the goods before they are released; the check happens with the container standing still.

This is why the sequence matters more than the paperwork: due diligence, then statement, then reference number, then customs declaration. Any order other than that one produces a shipment that cannot be released.

Two features make this heavier than the headline number:

• It is turnover, not margin, and Union-wide. The calculation follows the aggregate turnover rules in Article 5(1) of Regulation (EC) No 139/2004, so a group's turnover, not the importing entity's.
• Judgments are published. The Commission publishes a list of final judgments against legal persons, with the name, the date, a summary of the conduct and the penalty. Member states notify them within thirty days.

There is also a penalty that only bites the careful: a serious or repeated infringement can cost you the right to use the simplified due diligence of Article 13, which is the relief that made low-risk sourcing cheap in the first place.

So there is a three-year window in which two regimes run side by side over different stock, and the dividing line is the production date of the wood, not the date you bought it. Three consequences:

• Know the production date of your timber. Before or after 29 June 2023 decides which regime the goods sit in until the end of 2029.
• An EUTR due diligence system is not an EUDR one. The old regime asked about legality; the new one asks about legality and deforestation, with geolocation and a filed statement.
• Small operators lose the extra six months for these goods. The later date of 30 June 2027 explicitly does not cover products that were in the Annex to Regulation (EU) No 995/2010.

“Adequately conclusive and verifiable” is the phrase that decides audits, and it is doing real work. A supplier declaration that repeats the requirement back to you is neither conclusive nor verifiable. What tends to satisfy it:

• Documents from the country of production: land titles or use rights, harvest permits, tax and export records; the things a competent authority could check with the issuing body.
• Independent observation: satellite or aerial analysis of the plots against the 31 December 2020 baseline, with the method and the date recorded.
• A chain that reconciles: the quantity from those plots has to be capable of producing the quantity in your consignment. Volume reconciliation is where mixed and laundered lots fall over.

Certification schemes can be evidence in this file. They are not a substitute for it: the regulation puts the responsibility on the operator who submits the statement, and no scheme takes that over.

Seven questions that separate a supply-chain due diligence provider from a certificate seller:

• Do you collect geolocation from my suppliers, or do you process what I collect? These are different services at very different prices, and the first is the one that takes months.
• Do you submit the due diligence statement in my name, and under what mandate? An authorised representative may submit on the operator's behalf under Article 6, but the operator keeps responsibility for compliance.
• How do you test the plots against 31 December 2020, and can I see the method?
• How do you handle volume reconciliation for mixed lots?
• What do I get if a competent authority checks me? Ask for the file, not a certificate.
• Who pays if the statement is wrong? Read that clause before the price.

If you want us to build the list, say so; we add sectors where we can verify what each provider publishes about itself, and not before.