EUDR, the EU Deforestation Regulation (Regulation (EU) 2023/1115), covers every company that, as part of its business, places a product made from cattle, cocoa, coffee, oil palm, rubber, soya or wood on the EU market, sells it on in the EU or exports it, if the product is on the law's list.
Size does not take a company out. It decides how much the company has to do and from when, because only the first company in the chain files a due diligence statement.
Below are the four roles EUDR gives companies, the products that bring a company in, what each role has to do and the date each one starts.
EUDR does not stop at the company that imports raw coffee or timber. A chocolate brand, a wholesaler of paper goods and a shop selling wooden chairs can all be covered, because the law follows the product through every sale inside the EU.
To guide you the best way, it helps to know where your company is based, because EUDR decides who carries the due diligence differently for a company in the EU and one selling into it from abroad.
Is your company established in the EU?
Pick your answer below for the right guidance.
Key facts on who EUDR covers
Below are the six facts that decide whether EUDR reaches a company.
| Fact | What the law says |
|---|---|
| Law | Regulation (EU) 2023/1115, the EU Deforestation Regulation, binding directly in every EU country |
| Products | Those made from cattle, cocoa, coffee, oil palm, rubber, soya or wood and listed by customs code in Annex I |
| Companies | Any company that places a listed product on the EU market, makes it available there or exports it, as part of its business |
| Cut-off date | The land must not have been deforested after 31 December 2020 |
| Applies from | 30 December 2026, or 30 June 2027 for micro and small operators established by 31 December 2024, except for timber products already under the old EU Timber Regulation |
| Last changed | Delegated Regulation (EU) 2026/2102, published on 17 September 2026 |
The facts follow the consolidated text in EUR-Lex's record of the EU Deforestation Regulation, in its version of 18 September 2026, which includes all three amendments so far. The European Commission's EUDR page has its official guidance.
For what the law is and why it was made, see the glossary entry on the EU deforestation regulation.
The four roles EUDR gives a company
EUDR does not ask every company for the same thing. Article 2 sorts the companies a product passes through into four roles, and the role decides the duties.
A company only takes a role when it acts in the course of a commercial activity. Article 2(19) defines that as processing the product, distributing it to consumers or using it in the company's own business.
| Role | Who it is and what EUDR asks |
|---|---|
| Operator | The company that first places the product on the EU market, or exports it. It does due diligence and files a due diligence statement before selling |
| Downstream operator | A company that makes and sells new products from products already covered by a statement. It files no new statement but keeps supplier and customer details |
| Trader | Any other company in the chain that sells the product on in the EU. It has the same duties as a downstream operator |
| Micro or small primary operator | A micro or small producer in a low-risk country selling what it grew or raised itself. It files one simplified declaration instead of statements |
Placing on the market means the first time a product is made available in the EU (article 2(16)). Whoever does that is the operator, whether it imports the product or produces it inside the EU.
Every company after the operator works from the operator's reference number, which the operator has to pass down the chain with the product (article 4(7)).
Who takes the operator role in your case
Established in the EU. If you import a covered product, or are the first to sell one produced in the EU, you are the operator.
If you buy it from an EU company that already placed it on the market, you are a downstream operator when you make something new from it, and a trader when you sell it on as it is.
Selling from outside the EU. When a company established outside the EU places products on the EU market, the first company established in the EU that makes them available is treated as the operator (article 7).
That company carries the due diligence, so it needs the information behind every product from you, down to the plots of land where the commodities in it were produced.
Which products bring a company into EUDR
A company is only covered for the products on the list in Annex I, which names them by customs code. The list reaches much further than the seven commodity names, and since September 2026 it is clearer about what is left out.
In scope, for example:
- Live cattle, beef, cattle leather and hides
- Cocoa beans, cocoa butter and powder, and chocolate
- Coffee, and from 30 December 2027 also coffee extracts and concentrates
- Palm oil and a growing list of palm oil derivatives
- Wood and products of wood, such as plywood, wooden pallets and crates, and wooden seats
- Wood pulp, and paper and paperboard products
Out of scope:
- Packaging that is used only to support, protect or carry another product and goes with that product, whether it is single-use or reusable, in paper, paperboard or wood
- Letters, marketing and information material that only accompanies another product
- Used and second-hand products of wood and paper, including wooden furniture
- Paper and pulp made from recovered waste and scrap
- Goods made entirely from material that has reached the end of its life and would otherwise be waste
- Printed products such as books and newspapers, which were taken off the list in December 2025
- Products produced before 29 June 2023, the day EUDR entered into force
Packaging that falls outside EUDR is still covered by the EU's packaging rules and by EPR in each country where it is sold, so a company can be out of EUDR for its boxes and still owe registrations for them.
Six steps for a company that is the operator
The steps below follow one product from the first check to the sale, with the article behind each duty. Downstream operators, traders and small primary operators do less, as the end of this section explains.
Step 1. Check your products against Annex I
Put every product you buy in or sell next to the customs codes in Annex I. Then test each match against the exclusions in the same annex, such as packaging that only carries another product, or second-hand goods.
The products left over are the ones EUDR covers for your company. Write down which of them you place on the market first, because those are the ones the next five steps apply to.
Step 2. Collect the information behind each product
Before a product goes on sale, article 9(1) asks the operator to collect, organise and keep a set of information for each product, with evidence. It is traceability all the way back to the land.
- A description with the trade name and type, and for wood the species
- The quantity you place on the market or export
- The country of production
- The geolocation of every plot of land where the commodities in it were produced, and for cattle every place where the animals were kept
- The date or time range of production
A geolocation is a latitude and longitude with at least six decimals. A plot of more than four hectares, other than for cattle, has to be traced as a polygon round its edge (article 2(28)). Keep it all for five years.
Step 3. Assess the risk
As the second part of due diligence, article 10 asks you to check the information you collected and decide whether there is a risk that the product breaks the three conditions in article 3: deforestation-free, produced legally and covered by a statement.
The law names what goes into that judgement, from the risk level of the country of production to how complex the supply chain is and how easily products of unknown origin could be mixed in.
Countries count as standard risk until the Commission classifies them as low or high risk (article 29). Write the assessment down and review it at least once a year (article 10(4)).
There is a lighter route. When every commodity in the product comes from a country classified as low risk, this step and the next fall away, as long as you can show the risk of mixing with other origins is negligible (article 13).
Step 4. Reduce any risk you find
If the assessment finds more than a negligible risk, article 11(1) asks you to bring it down before selling. The law names three kinds of measure.
- Asking your suppliers for more information, documents or data
- Carrying out independent surveys or audits
- Supporting your suppliers, smallholders in particular, through capacity building and investment
A product that still carries more than a negligible risk cannot be placed on the market or exported (article 4(4)). An operator that is not an SME also needs a compliance officer at management level and an independent audit function (article 11(2)).
Step 5. Submit the due diligence statement
Submit a due diligence statement through the EU's information system before you sell or export, and you get a reference number for it (articles 4(2) and 33).
By submitting it you take responsibility for the product meeting the law (article 4(3)). Keep your statements for five years.
You may mandate an authorised representative established in the EU to submit the statement for you, but the responsibility stays with you (article 6).
Step 6. Pass the reference number on and stay alert
Your duties do not end with the statement. Two more follow the product after it leaves you.
- Pass the number on. Give the reference number of each statement to the downstream operators and traders you sell to (article 4(7)). It is what lets them sell the product on without a statement of their own.
- Report new concerns. If you later learn that a product you sold may not comply, tell the authorities in the countries where you sold it straight away, and the companies you supplied (article 4(5)).
What the other three roles have to do
The companies further down the chain, and the smallest producers, carry lighter duties set out in articles 4a and 5.
- Downstream operators and traders file no statement. They collect and keep for five years the name, postal and email address of their suppliers, the reference numbers when the supplier is the operator, and the same details of the companies they sold to (article 5(3) and (4)).
- Larger downstream operators and traders, those that are not SMEs, also register in the information system before they sell (article 5(2)). When there is a substantiated concern, they check that due diligence was done and found no or only a negligible risk (article 5(6)).
- Micro or small primary operators submit one simplified declaration, get a declaration identifier, and may give the postal address of their plots instead of a geolocation (article 4a). A micro company that is an operator may also let the next, larger company in the chain submit for it (article 6(3)).
Every company in the chain that learns a product may not comply has to tell the authorities straight away (articles 4(5) and 5(5)).
When EUDR starts for each company
EUDR has been postponed twice, and its start now depends on the size of the operator and on the product. The dates below are the ones in the law today.
The table below lists every EUDR date and what happens on it, starting with the day the law came into force in June 2023.
| Date | What happens |
|---|---|
| 29 June 2023 | EUDR entered into force. Products produced before this date are not covered |
| 30 December 2026 | The core rules apply. The old EU Timber Regulation (EU) No 995/2010 is repealed |
| 30 June 2027 | The core rules apply to operators that are micro or small companies established by 31 December 2024, except for timber products already under the old Timber Regulation |
| 30 December 2027 | The products added in September 2026 come in, such as coffee extracts, frozen cattle tongues and several palm oil derivatives |
| 31 December 2029 | The old Timber Regulation stops applying to timber produced before 29 June 2023 and placed on the market from 30 December 2026 |
How EUDR has changed since 2024
Three changes have reshaped EUDR since it was adopted in 2023, so a supplier letter or a guide written before them may name the wrong companies or dates.
- December 2024. Regulation (EU) 2024/3234 moved the start from 30 December 2024 to 30 December 2025.
- December 2025. Regulation (EU) 2025/2650 moved it again, to 30 December 2026 and 30 June 2027. It created the downstream operator role, so only the first operator files a statement, gave small producers in low-risk countries a simplified declaration, and took printed products off the list.
- September 2026. Delegated Regulation (EU) 2026/2102, published on 17 September 2026, rewrote the product list. Packaging that only carries another product and second-hand wood and paper products were taken out, and new products were added from 30 December 2027.
Will EUDR be delayed again? The dates above are the ones that have been adopted, and until a further change is adopted and published they are the dates that count.
What a company risks under EUDR
Each EU country sets its own penalties and enforces them through its own authorities, but article 25 tells every country what those penalties must include.
The fines have to match the environmental damage and the value of the products. For a company, the maximum fine must be at least 4 % of its total annual EU-wide turnover, which is a floor for the size of the maximum, not a fixed fine.
On top of fines, the authorities can confiscate the products and the revenue made from them, and exclude a company from public procurement and public funding for up to 12 months.
For serious or repeated infringements they can temporarily ban a company from selling or exporting the products, and take away its right to the lighter low-risk route (article 25(2)).
The Commission also publishes a list of final judgments against companies, with the company's name and the penalty (article 25(3)).
Where Repax fits next to EUDR
EUDR is one of several EU rules a product meets on its way to a customer. Its packaging, and any electronics or batteries in it, also carry EPR duties in each country where it is sold, as the guide to EPR registration in Europe explains.
Repax does not file EUDR due diligence statements or collect geolocation data. It handles the EPR side, the registrations and reports for each market.
Not sure if you are registered in every country you sell in?
We will run a demo on a representative product and discuss your specific EPR mix.
- How many EU markets do you sell into?
- Do you import from outside the EU?
Frequently asked questions about EUDR
Below are the eight questions companies ask most about who EUDR covers, each answered on its own.
What is EUDR?
EUDR is the EU Deforestation Regulation, Regulation (EU) 2023/1115. It bans products made from cattle, cocoa, coffee, oil palm, rubber, soya and wood from the EU market and from export unless they are deforestation-free, legally produced and covered by a due diligence statement.
Which companies does EUDR apply to?
EUDR applies to every company that, as part of its business, places a product on its Annex I list on the EU market, sells it on in the EU or exports it. The first is the operator, the rest are downstream operators or traders.
Does EUDR apply to small companies?
Yes. Size changes the date and the workload, not whether the law applies. Micro and small operators established by 31 December 2024 start on 30 June 2027, and downstream operators and traders that are SMEs do not register in the information system.
Does EUDR apply to companies outside the EU?
EUDR covers products placed on the EU market, wherever they come from. When a company outside the EU places products on the market, the first company established in the EU that makes them available is treated as the operator and carries the due diligence.
Who submits the due diligence statement under EUDR?
Only the operator, the company that first places the product on the EU market or exports it. Downstream operators and traders file no statement of their own. They keep the operator's reference number and the details of their suppliers and customers for five years.
Is paper packaging covered by EUDR?
Paper and paperboard products are covered, but packaging used only to support, protect or carry another product and presented with it is not. Delegated Regulation (EU) 2026/2102 added that exclusion for paper and paperboard in September 2026, for both single-use and reusable packaging.
When does EUDR come into force?
EUDR entered into force on 29 June 2023, but its core rules apply from 30 December 2026. Operators that are micro or small companies established by 31 December 2024 have until 30 June 2027, except for timber products already under the old EU Timber Regulation.
What are the fines under EUDR?
Each EU country sets its own fines, but for a company the maximum must be at least 4 % of its total annual EU-wide turnover. Products and revenues can be confiscated, and companies shut out of public contracts and funding for up to 12 months.
