EUDR: Who is affected and what applies from 30 December 2026

What is the EUDR?

The EUDR (EU Deforestation Regulation, Regulation (EU) 2023/1115) is the EU regulation on deforestation-free supply chains. From 30 December 2026 it prohibits placing seven commodities and products derived from them on the EU market, or exporting them from the EU, unless they are demonstrably deforestation-free and legally produced. Proof is provided through a due diligence statement with geolocation data of the plots of production. The commodities are cattle, cocoa, coffee, oil palm, rubber, soya and wood.

The core of the regulation is Article 3:

“Relevant commodities and relevant products shall not be placed or made available on the market or exported, unless all the following conditions are fulfilled: (a) they are deforestation-free; (b) they have been produced in accordance with the relevant legislation of the country of production; and (c) they are covered by a due diligence statement.” — Art. 3 Regulation (EU) 2023/1115

“Deforestation-free” means: the land was not deforested after 31 December 2020, and for wood, no forest degradation took place.

Who is affected?

Every company that places relevant commodities or products listed in Annex I on the EU market, makes them available, or exports them:

• Operators: anyone who first places a product on the EU market or exports it. That is the importer, but also the German sawmill or the roaster processing green coffee.
• Traders: anyone who resells relevant products within the EU, such as a wholesaler of furniture, paper, tyres or chocolate.

The list of derived products is long: furniture, paper and board, wooden packaging, books, tyres, leather goods, chocolate, cosmetics containing palm oil, soya feed. A delegated act of 13 July 2026 adjusts Annex I: soluble coffee and palm oil derivatives are added, hides and leather as well as retreaded tyres are removed. Newly added products get a transition period until 30 December 2027; the objection period for Parliament and Council is still running.

Not affected: companies that neither trade, process nor export any of the seven commodities or listed products. Buying office supplies or coffee for your own canteen makes you an end user, not an operator. Products produced before 29 June 2023 are exempt; wood from that period has its own transitional rule (Article 37).

What applies from when?

The Commission’s review of 4 May 2026 explicitly confirmed the dates. There is no “no-risk” country category. It remains at three country risk levels (low, standard, high) with simplified due diligence for low-risk countries.

Which concrete obligations arise?

For operators (and large traders, who are treated like operators):

1. Collect information: product description, quantity, country of production, geolocation of all plots of production (as polygons for plots above four hectares), production period, supplier data and evidence of legality.
2. Assess risk: country risk, deforestation prevalence, corruption, supply chain complexity, indigenous rights. Outcome: no or negligible risk, otherwise no market release.
3. Mitigate risk: additional documents, independent audits, change of supplier, until the risk is negligible.
4. Submit a due diligence statement: electronically in the EU information system TRACES, before placing on the market. It receives a reference number.
5. Document and retain: five years, available to the competent authority at any time. In Germany that is the Federal Office for Agriculture and Food (BLE).
6. Report annually: public report on the due diligence system (not required for SMEs).

For downstream companies and SME traders, things became easier at the end of 2025: anyone processing a product that was already placed on the market with a due diligence statement may use the upstream reference number instead of running a new due diligence process. Micro and small traders only have to keep supplier and customer data.

Common misconceptions

• “We don’t import, so it doesn’t concern us.” The EUDR applies to placing and making available, not to importing. Coffee from a German roaster and spruce from the Black Forest are covered.
• “Our FSC certificate is enough.” Certificates can be part of the risk assessment. They do not replace the due diligence statement or the geolocation data.
• “Packaging doesn’t count.” Wooden packaging such as pallets and crates are relevant products as long as they are traded as goods. Only packaging used purely to protect other products is exempt.
• Talking to suppliers too late. The geolocation data comes from the plantation or forest operation, often three or four tiers away. Ask in December 2026 and you will have no reference number in January.

How SCRM Guard helps

The EUDR compliance module on the platform maps your suppliers and commodity groups to the relevant commodities, collects geolocation data, legality evidence and reference numbers from suppliers via email requests, and keeps the processing status per supplier traceable. Event monitoring watches the countries of production for deforestation and legal risks and reports changes in Microsoft Teams. Every assessment, every follow-up and every submitted statement lands in the audit trail you can show the BLE or your customer.

If you have no team for this, we run it as a full service: we identify the affected commodity groups, handle supplier communication, assess the risks and prepare the due diligence statements. You approve and keep the overview. And we also tell you which of your products do not fall under the regulation at all.

Sources

• Regulation (EU) 2023/1115 (EUDR), consolidated text, EUR-Lex (26 Dec 2025)
• Regulation (EU) 2025/2650 amending the EUDR (postponement, simplification) (23 Dec 2025)
• European Commission: EUDR review COM(2026) 191 (04 May 2026)
• European Commission: delegated act on product scope (Annex I) (13 Jul 2026)

This page is an editorial briefing for procurement and compliance teams in mid-sized companies, not legal advice. We check deadlines and thresholds against primary sources; the review date is shown at the top of the page.