EUDR (Regulation 2023/1115) establishes rules governing the placing on the market and making available on the Union market, as well as the export from the EU, of certain goods.

These goods may not be placed on the market, made available on the EU market, or exported from it unless all of the following conditions are met:

• they do not cause deforestation,
• they were produced in accordance with the relevant legislation of the country of production, and
• a due diligence statement has been submitted in relation to them.

Goods covered by the EUDR

Goods (so-called relevant commodities) covered by the EUDR are:

• cattle, cocoa, coffee, oil palm, rubber, soy, and wood.

The regulations also cover relevant products, i.e. products:

• containing the above commodities as ingredients,
• produced from the above raw materials, or
• obtained by feeding animals with those commodities.

All relevant commodities and products are listed in Reed Annex I to the EUDR Regulation.

Therefore, for a given good to be subject to the EUDR, it must simultaneously:

• be listed in Annex I, and
• contain or be produced from a relevant commodity (or relevant product) listed in that Annex.

The EUDR does not provide for any quantitative thresholds — every good listed in Annex I is subject to EUDR requirements, regardless of quantity.

Entities covered by the EUDR

The EUDR introduces two main categories of entities:

Operators – entities that:

• place relevant products on the market for the first time (make them available on the Union market in the course of a commercial activity), or
• export them outside the EU.

Traders – all other participants in the supply chain who, in the course of a commercial activity, make relevant products available on the market (for the purposes of distribution, consumption, or use in the EU).

Obligations under the EUDR

The scope of obligations depends on the role of a given entity in the supply chain.

The main obligation is to exercise due diligence (DDS), which includes:

• collecting information, data, and documents relating to the product,
• risk assessment – verifying the collected information in order to determine whether there is a risk of non-compliance of the products with EUDR requirements,
• implementation of risk mitigation measures – if the assessment shows that the risk is more than negligible.

Before placing relevant products on the market (or exporting them), it will be necessary to submit a due diligence statement, covering part of the collected information.

Traders, on the other hand, must ensure that due diligence has been exercised at earlier stages of the supply chain and submit their own statement referring to previous declarations (with simplifications provided for micro and small enterprises).

Dates of application

• From 30 December 2025 – EUDR provisions will apply to all entrepreneurs.
• From 30 June 2026 – the provisions will also apply to micro and small enterprises.

The obligations do not apply to products produced before 29 June 2023.

Sanctions

Failure to comply with EUDR obligations may result, among others, in:

• confiscation of relevant products,
• confiscation of revenues obtained from transactions,
• other administrative and financial penalties.

Start verifying today whether your company may be subject to the EUDR!