The EU Deforestation Regulation (EUDR) starts applying to large and medium operators on 30 December 2026 — less than six months away. For importers of wood, furniture, paper, coffee, cocoa and other covered products, that means something very concrete: without a Due Diligence Statement (DDS) and its EUDR reference number attached to the customs declaration, the import cannot be processed. This guide summarises the obligations and the preparation steps.
Not sure whether you're in scope? Take the quick CBAM / EUDR test — 5 questions, under a minute.
What EUDR requires: the three conditions
A relevant product may be placed on the EU market or exported only if it meets all three conditions (Art. 3):
- Deforestation-free — it does not come from land deforested after 31 December 2020; for wood, also no forest degradation after that date.
- Legality — it was produced in accordance with the relevant legislation of the country of production.
- Covered by a DDS — or by a simplified declaration, filed in the EU Information System.
Who and what is in scope
EUDR covers seven commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood — plus the derived products listed in Annex I, identified by CN code. For most importers, the typical categories are wood and wood products (ch. 44), paper, paperboard and pulp (ch. 48) and furniture (ch. 94).
There is no de minimis threshold. Unlike CBAM, any quantity or value is in scope. Scope is decided by the CN code in Annex I, not by the presence of the material — a product with an unlisted code is out of scope even if it contains wood or rubber.
The role is determined per product, not per company: whoever first places a relevant product on the EU market (or exports it) is an operator and carries the due diligence and DDS obligations. The December 2025 simplification created two categories with reduced obligations: the downstream operator (manufactures products from materials already fully covered by a DDS — no own DDS required) and the MSPO (micro or small primary operator in low-risk countries, with a single simplified declaration).
Application dates
| Who | Applies from |
|---|---|
| Large and medium operators | 30 December 2026 |
| Micro and small (status on 31 Dec 2024) | 30 June 2027 |
| Micro and small already covered by EUTR (timber) | 30 December 2026 |
The due diligence obligations (Art. 9–11)
1. Information collection (Art. 9)
- Geolocation of the plot of origin: coordinates with at least 6 decimal places; plots over 4 ha described as polygons;
- origin and supply chain trail;
- legality documents: permits, authorisations, harvesting rights;
- the harvesting or production period;
- product description, volume and CN code.
2. Risk assessment (Art. 10)
The operator assesses whether the risk of non-compliance is "negligible", combining:
- geospatial risk — did the plot lose forest after 31.12.2020? Does it overlap protected areas?
- country risk — the Commission's risk benchmarking, plus governance and legality indicators;
- documentary risk — completeness and consistency of the collected data (for example, declared country vs. the country derived from coordinates).
3. Risk mitigation (Art. 11)
If the risk is not negligible, the DDS cannot be filed. The operator must obtain additional documents, clarify the information with the supplier or perform checks or an external audit — and document every action. Only once the risk becomes negligible can the statement be generated.
DDS, TRACES and customs
The due diligence statement is filed electronically in the EU Information System (TRACES) and receives a reference number that is attached to the customs declaration. The practical flow of an import: identify the product (CN code in scope), collect data and documents from the supplier, validate completeness and consistency, run the geospatial check, assess the risk, apply mitigation if needed, generate the DDS — and only then go to customs.
The entire file — data, documents, checks, decisions — must be archived for at least 5 years and produced during inspections. Non-compliance brings blocked imports, confiscation of goods, penalties and, in practice, loss of access to the EU market.
How to prepare: checklist
- Inventory your imported products and check CN codes against Annex I.
- Determine your role per product: operator, downstream operator or trader.
- Map suppliers by country of origin and request plot geolocation and legality documents.
- Define a standard collection form for suppliers — it works even with suppliers without digital systems.
- Choose your geospatial verification approach (post-2020 deforestation analysis on the received coordinates).
- Document your risk assessment and mitigation procedure.
- Prepare TRACES registration and test DDS generation on real cases before the deadline.
Supplier data collection, validations, geospatial checks and DDS generation form a repetitive process with clear rules — exactly the right profile for automation. See EUDR Manager, our solution for EUDR compliance, or our consulting services if you want to start by mapping the process.