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EUDR (EU Deforestation Regulation): products covered, due diligence and timeline

From 30 December 2026, cattle, cocoa, coffee, oil palm, rubber, soya, wood and part of their derived products may only be placed on the EU market or exported if they are deforestation-free, legal and covered by a due diligence statement. Customs will check the reference of that statement at clearance. Here are the products covered, the obligations and the timeline.

Updated Nov 7, 2026

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What the regulation requires

Regulation (EU) 2023/1115 on deforestation-free products (EUDR) replaces the EU Timber Regulation. A relevant product may only be placed on the Union market or exported if it meets three conditions:

  • It is deforestation-free: produced on land that has not been deforested after 31 December 2020 and, for wood, without forest degradation
  • It was produced in accordance with the legislation of the country of production: land use rights, environment, labour law, indigenous peoples' rights…
  • It is covered by a due diligence statement, or by a simplified declaration

Products covered

The regulation targets seven commodities and the derived products listed, code by code, in its Annex I. A product that is not in the annex is not covered, even if it contains a relevant commodity. Main headings:

  • Cattle: live animals (0102 21, 0102 29), meat (0201, 0202) and offal (0206 10, 0206 22, 0206 29)
  • Cocoa: beans, paste, butter, powder and chocolate (1801 to 1806)
  • Coffee: green, roasted or decaffeinated (0901)
  • Oil palm: palm nuts and kernels (1207 10), palm and palm kernel oil (1511, 1513 21, 1513 29), oilcake (2306 60) and some derivatives (glycerol, fatty acids and fatty alcohols)
  • Soya: beans (1201 90), flour (1208 10), oil (1507) and oilcake (2304)
  • Rubber: natural rubber (4001) and some articles, including new tyres (4011), inner tubes (4013), clothing and gloves (4015)
  • Wood: wood and articles of wood (chapter 44), pulp and paper (chapters 47 and 48), wooden furniture and seats (9401, 9403), prefabricated wooden buildings (9406)

Printed products (books, newspapers) left the scope in December 2025. Since 18 September 2026, Delegated Regulation (EU) 2026/2102 has also removed cattle hides, skins and leather, conveyor belts and other articles of vulcanised rubber, aircraft and car seats, and soya beans for sowing. It adds soluble coffee, frozen cattle tongues and palm oil derivatives from 30 December 2027. Packaging, samples and second-hand products are excluded.

Who has to do what?

  • The operator who places the product on the Union market for the first time, in particular the importer who releases it for free circulation, or who exports it: they carry out due diligence and submit the statement
  • Downstream operators and traders: since the December 2025 revision, they no longer submit statements; they keep the details of their suppliers and customers for five years and, where their supplier is the original operator, the reference of its statement
  • Micro and small primary operators, who place on the market what they produced themselves: they can submit a one-off simplified declaration

Due diligence in three steps

  • Collect information: description, quantity, country of production, suppliers and the geolocation of every plot of land where the commodity was produced
  • Assess the risk of non-compliance, taking into account in particular the classification of the country of production (low, standard or high risk) published by the Commission
  • Mitigate the risk until it is zero or negligible: additional information, independent audits, change of supplier

For products coming only from countries classified as low risk, simplified due diligence is enough: risk assessment and mitigation are not required, unless there is information to the contrary. The statement is submitted in the Commission's information system, which gives it a reference number; supporting evidence is kept for five years.

At customs: the statement reference

When a relevant product is cleared, for import or export, the customs declaration must state the reference number of the due diligence statement. Customs checks this reference in the information system; a product without a valid reference, or flagged as risky, can be held.

The document codes used in declarations include:

  • C716: due diligence statement submitted for import or export
  • C717: reference of a statement submitted earlier, for example further up the supply chain
  • Y129: goods not covered by the regulation, where the code covers only some of the products
  • Y132: Annex I product produced before 29 June 2023
  • Y133: product made from materials that have completed their life cycle (recycling)
  • Y142: exemption for non-commercial activities

In France, these codes are already in the DELTA IE code lists. A wrong reference or a missing document code can block release.

Timeline

  • 29 June 2023: Regulation (EU) 2023/1115 enters into force
  • December 2025: Regulation (EU) 2025/2650 postpones application by one year and eases downstream obligations
  • 18 September 2026: Delegated Regulation (EU) 2026/2102, which amends the product list, enters into force
  • 30 December 2026: application to large and medium-sized companies, and to micro and small companies for wood products already covered by the Timber Regulation
  • 30 June 2027: application to other micro and small companies
  • 30 December 2027: soluble coffee, frozen cattle tongues and palm oil derivatives come into scope

Penalties

Member States set the penalties. They must include fines of up to at least 4% of the company's annual turnover in the Union, confiscation of the products and revenues, and temporary exclusion from public procurement.

How to prepare

  • Check the Combined Nomenclature code of each product and compare it with Annex I, taking “ex” headings into account
  • Identify the products concerned in your purchases, and the suppliers who will need to provide geolocation data
  • Create your account in the Commission's information system
  • Agree with your forwarder how reference numbers will be passed on for each customs declaration
  • Keep the due diligence evidence for five years

Frequently asked questions

When does the EUDR apply?

On 30 December 2026 for large and medium-sized companies, and on 30 June 2027 for micro and small companies, except for wood products already covered by the Timber Regulation, which are concerned from 30 December 2026.

How do I know whether my product is covered?

Compare its Combined Nomenclature code with the list in Annex I of the regulation. Only the codes listed are covered; for an “ex” heading, only part of the products are.

Who submits the due diligence statement?

The operator who places the product on the Union market for the first time or exports it, usually the importer. Downstream operators and traders no longer submit statements since the December 2025 revision.

What must the customs declaration state?

The reference number of the due diligence statement (document codes C716 or C717), or an exemption code such as Y129 when the goods are not covered.

Is leather still covered?

No. Delegated Regulation (EU) 2026/2102 removed cattle hides, skins and leather (4101, 4104, 4107) from Annex I as of 18 September 2026. Live cattle, meat and offal remain covered.

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