Large and medium-sized enterprises
Original date
30 December 2024
Current date
30 December 2026
The EUDR imposes due diligence obligations on businesses that place on the EU market, makeavailable on that market, or export from the Union commodities linked to deforestation, to ensure thatthey do not contribute to deforestation or forest degradation worldwide.
The EUDR covers seven groups of commodities and their relevant products. Every product covered must be deforestation-free (cut-off date: 31 December 2020), produced in accordance with the relevant legislation of the country of production, and accompanied by a due diligence statement.
Legal basis: Regulation (EU) 2023/1115 of 31 May 2023 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 and repealing Regulation (EU) No 995/2010.
The EUDR has been postponed twice. The current dates depend on the size of the business; use the toggle to see the timeline for each category.
We support businesses at every stage of EUDR preparation, from determining your status through to full readiness to submit a DDS.
Determining entity status
Establishing whether you act as an operator, a downstream operator, or a trader, and what scope of obligations follows from that.
Product inventory
Identifying the products in your portfolio that are covered by the EUDR, and assessing your regulatory exposure.
Supply chain mapping
Mapping supply chains down to the farm/plot level, support in collecting geolocation data, and supplier onboarding.
Due diligence and DDS implementation (due diligence statement)
Designing the due diligence process (Articles 9 to 11) and pilot submission of a DDS in the EUDR system.
Training and procedures
Training teams, updating supplier contracts, and preparing internal compliance procedures.
Legislation monitoring
Ongoing tracking of amendments to the EUDR and of country reclassification, and of Polish legislation implementing the EUDR regime, with recommendations for your operations.
Regulation (EU) 2025/2650 of 19 December 2025 introduced not only the second postponement but also a fundamental reform of the structure of obligations.
The "first operator" model
The full due diligence obligation rests with the operator that first places the product on the EU market or exports it. Downstream operators do not submit their own statements (DDS).
New model
Simplifications for micro- and small businesses
Micro- and small enterprises from low-risk countries may submit a one-off simplified declaration instead of a full DDS, and may replace geolocation data with a postal address.
Poland: low risk
Changes to product scope
Printed products (Chapter 49 of the Combined Nomenclature) have been excluded from scope.
Chapter 49: excluded
Downstream operator
A new category of entity, the "downstream operator," has been introduced, with limited administrative obligations.
New entity covered by the rules
Regulation (EU) 2025/2650 of 19 December 2025, implementing Regulation 2025/1093
The first step is to determine your entity status; the scope of your obligations depends on it. Select a role to see the details.
Draft Polish act implementing the EUDR (UC101): an obligation for all roles in Poland
Entities operating in Poland must include the reference number of the due diligence statement (or the identifier of the one-off simplified declaration) in every commercial offer.
Watch the free webinar and learn how to identify and mitigate key EUDR risks before an enforcement authority does.
Since May 2025, a classification of countries by deforestation risk level has been in force, introduced by implementing Regulation 2025/1093.
High risk
9%
of operators subject to mandatory checks
Belarus, Myanmar, North Korea, Russia.
Standard risk
3%
of operators subject to checks
incl. Brazil, Indonesia, Malaysia, Colombia.
Low risk
1%
of operators subject to checks
All 27 EU Member States, as well as the USA, United Kingdom, Canada.
Poland has been classified as low-risk; simplified obligations for commodities sourced within its territory.
The risk level of the country a commodity originates from directly affects the scope of due diligence requirements.
The first reclassification may take place in 2026, with a minimum adaptation period.
An operator placing a product on the EU market must carry out the full, three-step due diligence process.
Information collection
Geolocation data for the plots of production, product data, supplier data, and documents confirming the legality of production.
Risk assessment
Analysis of whether the product may originate from land deforested after 31 December 2020 or was produced not in accordance with the relevant legislation of the country of production.
Risk mitigation
Implementation of risk-reducing measures, including supplier audits and independent verification.
The EUDR applies directly in Poland, but requires supplementary national provisions designating the enforcement authorities, procedures, and penalties. The Ministry of Climate and Environment published draft act UC101 (around 10 April 2026).
Procedures for checks, DDS submission, and interim measures (seizure of commodities), as well as corrective actions.
Detailed administrative penalties.
An obligation to include the DDS reference number or the identifier of the simplified declaration in every commercial offer.
Legislative status
Draft published around 10 April 2026 and entering the consultation and consensus-building phase. Next steps: review, the Standing Committee of the Council of Ministers, adoption by the Council of Ministers, and passage through the Sejm.
Three competent authorities
The draft assigns oversight competences by commodity group.
The national coordinator will be the minister responsible for the environment.
For large and medium-sized entities, we recommend the following timeline of preparatory actions.
Inventory and team
Determining entity status, product inventory within the scope of the EUDR, setting up a compliance team, and selecting an IT tool.
Chain mapping
Mapping supply chains down to the farm/plot level, data and information collection, supplier onboarding, and staff training.
DDS pilot
Pilot submission of a DDS in a test environment and updating supplier contracts.
30 December 2026
Full compliance: readiness to submit a DDS in the EUDR system.
Several factors may affect your preparation timeline and the scope of your obligations; it is worth monitoring them on an ongoing basis.
Since 16 February 2026, the Commission has imposed temporary access restrictions in order to update the system. The system was made available again in July 2026, allowing companies to begin familiarising themselves with its features.
The first revision of the risk classification is planned for 2026. A change in a supplier's country risk category may force an expansion of due diligence procedures at minimal notice.
Periodic reviews of the rules by EU bodies, carried out up to 2030 and in subsequent years, carry the risk of further modifications. Ongoing monitoring of the regulatory framework is essential.
The financial penalties provided for are very severe and may reach a high percentage of a business's annual turnover.
