EUDR for Exporters: EU Deforestation Rules from 30 December 2026, Geolocation and Buyer Data
The EU Deforestation Regulation (EUDR, Regulation (EU) 2023/1115) lets cattle, cocoa, coffee, oil palm, rubber, soya and wood, and products made from them, be placed on the EU market or exported from it only if they are deforestation-free (produced on land not deforested after 31 December 2020), produced legally in the country of production and covered by a due diligence statement. After two postponements it applies from 30 December 2026 to most companies and from 30 June 2027 to most micro and small operators. The EU company that first places the product on the market files the statement, so exporters outside the EU will be asked for the geolocation of every plot of land where the commodity was produced and for evidence of legality.
Checked against official sources: 2026-10
At a glance
What the EUDR requires
Regulation (EU) 2023/1115 replaces the EU Timber Regulation and covers seven commodities, cattle, cocoa, coffee, oil palm, rubber, soya and wood, and the products made from them that are listed by HS code in its Annex I, such as chocolate, palm oil, natural rubber products, wooden furniture, paper and leather. A relevant product may be placed on the EU market, made available on it or exported from it only if three conditions are met:
- Deforestation-free: the commodity was produced on land that was not subject to deforestation after the cut-off date of 31 December 2020, and wood was harvested without forest degradation after that date.
- Legal: it was produced in line with the relevant laws of the country of production, such as those on land use rights, environmental protection, forest management, labour and human rights, third parties' rights, tax, anti-corruption and trade and customs.
- Covered by a due diligence statement submitted in the EU Information System before the product is placed on the market or exported.
New dates and the December 2025 changes
The EUDR was due to apply from 30 December 2024 and was postponed by a year in 2024. Regulation (EU) 2025/2650, published in December 2025, postponed it again and simplified it:
- From 30 December 2026: large and medium operators, downstream operators and traders of all sizes, and micro and small enterprises for products that were already covered by the EU Timber Regulation.
- From 30 June 2027: natural persons and micro and small enterprises for the other products.
- Only the operator that first places a product on the EU market submits the due diligence statement. Operators and traders further down the supply chain do not file statements; they register in the Information System and collect and keep the reference number of the first statement.
- Micro and small primary operators, such as farmers, submit a single simplified declaration instead of recurring statements.
- In its simplification review of 4 May 2026, the Commission confirmed these dates and did not propose further changes to the Regulation itself. It proposed adjusting the product list through a delegated act, for example adding soluble coffee and some palm oil derivatives and removing leather and retreaded tyres, with exemptions for samples, waste, used products and packaging. Check the current Annex I for your HS code.
Geolocation and the data your EU buyer will ask for
The due diligence statement must include the geolocation of all plots of land where the commodity was produced: latitude and longitude coordinates, and for plots of more than four hectares a polygon that marks the perimeter. Your EU buyer, as the operator, also needs:
- The product description, HS code and quantity (net mass, volume or number of units).
- The country of production and, for each plot, the date or period of production.
- The names and addresses of the suppliers and of the businesses the product was supplied to.
- Information showing that the product is deforestation-free and was produced legally, such as land titles or use rights, permits and certificates.
- For products from countries classified as low risk under the Commission's country benchmarking (Implementing Regulation (EU) 2025/1093), the operator may apply simplified due diligence, but it still needs the geolocation and the other information.
How the statement reaches customs
Relevant products entering or leaving the EU are checked against their due diligence statements: the customs declaration must give the reference number of the statement in the Information System. If the buyer cannot submit a statement because data is missing, the goods cannot be released for free circulation. Send the geolocation and the other information to your buyer well before shipment, and put the HS code, the net quantity and the country of production on the commercial invoice and packing list so that they match the statement.
Practical steps for exporters outside the EU
- Map your supply chain back to the farms, plantations or forest plots, and collect their coordinates and polygons.
- Keep evidence of the land's status since 31 December 2020, for example satellite imagery or monitoring reports, and of legal production.
- Segregate EUDR-compliant goods from other goods, so that each lot can be traced to its plots.
- Agree with each EU buyer the data format, who submits the statement and the deadline before shipment.
- Check the HS code of every product against Annex I, including processed products such as chocolate, instant coffee, furniture or tyres.
Step by step
- Check whether your products' HS codes are in Annex I to Regulation (EU) 2023/1115.
- Collect the geolocation of every plot of production, with polygons for plots of more than four hectares.
- Gather evidence that the land was not deforested after 31 December 2020 and that production was legal.
- Send the data to your EU buyer before shipment so that it can submit the due diligence statement.
- Show the HS code, net quantity and country of production on the invoice and packing list, matching the statement.
Documents you usually need
- Commercial invoice with the HS code, net quantity and country of production
- Packing list
- Geolocation file of the plots of production (points or polygons)
- Evidence of legal production: land titles or use rights, permits, certificates
- Reference number of the due diligence statement, once submitted
Common problems and how to avoid them
What to do: Map the plots before harvest, keep each lot separate, and do not mix untraced beans or fruit into lots for the EU.
What to do: Use the same HS code and net quantity on the invoice, packing list and the data you send for the statement.
What to do: Products from that plot are not deforestation-free under the EUDR and cannot be sold into the EU.
What to do: Annex I covers many derived products; check your HS code.
Sources
- Regulation (EU) 2023/1115 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 EUR-Lex
- Delay until December 2026 and other developments in the implementation of the EUDR Regulation European Commission, Access2Markets
- Report from the Commission on the simplification review of Regulation (EU) 2023/1115, COM(2026) 191 final European Commission, EUR-Lex
- Commission Implementing Regulation (EU) 2025/1093 (country benchmarking) EUR-Lex
Rules change often. This note is practical guidance based on the sources above, not legal advice. Confirm current requirements with the authority, your importer or a licensed customs broker before you ship.
Trade notes
Common questions
When does the EUDR apply?
From 30 December 2026 for large and medium operators, all downstream operators and traders, and micro and small enterprises for former EU Timber Regulation products; from 30 June 2027 for most micro and small operators. The Commission confirmed these dates in May 2026.
Does the EUDR apply to exporters outside the EU?
The legal obligation falls on the company that places the product on the EU market, usually the EU importer. But it can only do so with your data: the geolocation of the plots, the production dates and evidence of legality.
What is the EUDR cut-off date?
31 December 2020. The commodities must come from land that was not deforested after that date, and wood must be harvested without forest degradation after it.
Which products are covered by the EUDR?
Cattle, cocoa, coffee, oil palm, rubber, soya and wood, and the derived products listed by HS code in Annex I, such as chocolate, palm oil, rubber products, wooden furniture, paper and leather.
Who submits the due diligence statement?
Only the operator that first places the product on the EU market or exports it. Downstream operators and traders register in the Information System and keep the reference number of that statement.
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