Sell products with wood or natural rubber in the EU and you must prove where the raw material grew, down to the plot, and that the plot was not deforested after 31 December 2020. Large and medium companies from 30 December 2026, micro and small from 30 June 2027. The evidence sits with your suppliers; EUDR makes collecting it your job.
Key takeaways
Three conditions, all at once: legally produced, covered by a due diligence statement, and deforestation-free, meaning the land was not deforested after 31 December 2020.
No mass balance: one wood component without plot data bans the whole product from the EU market. Compliant and unknown material cannot be mixed.
Traceability to the plot: GPS coordinates for every forest plot, a point under 4 hectares, a polygon above it. Leather left the scope in July 2026.
Composites are the hard case: MDF, particleboard and plywood carry every species and every plot of every wood input.
What is EUDR?
The EU Deforestation Regulation, Regulation (EU) 2023/1115, is in force since 29 June 2023. It bans placing seven commodities and their products on the EU market, or exporting them, unless they are deforestation-free and legally produced. The seven: cattle, cocoa, coffee, oil palm, rubber, soya and wood.
The EUDR regulation binds the operator, the company that first places the product on the EU market, and to a lesser degree the traders after it. It sets no product standard. It sets an evidence standard: plot of origin, harvest date, species, legality, and a signed statement, for every shipment.
It is one of the EU product rules in these guides that ask for supplier evidence rather than product data.
EUDR news and status: the delay and the dates
Application has been delayed twice. The dates now in the regulation: 30 December 2026 for large and medium companies, 30 June 2027 for micro and small ones. Small companies that already handled timber under the EUTR keep the 30 December 2026 date.
On 13 July 2026 the Commission adopted a delegated act removing cattle hides, skins and leather from scope, with publication in the Official Journal expected in September 2026. Wood and natural rubber stay in. The EUDR delay is the part of this page most likely to move; we update this paragraph when it does.
Sector detail sits in the guides: EUDR for textiles and EUDR for furniture.
EUDR timber, rubber and leather: which products and materials are in scope
Terms to know · Due Diligence Statement
A formal declaration submitted via TRACES NT confirming that the products meet all EUDR requirements, including deforestation-free status and legality.
Scope follows the Combined Nomenclature codes in Annex I, not the product name. A sofa is in scope because of its frame, not because it is a sofa. Furniture, footwear and bag brands meet EUDR through wood and natural rubber; see the furniture, footwear and bags pages for where each starts.
In scope for furniture: particle board (CN 4410), fibreboard and MDF (CN 4411), plywood (CN 4412), wooden seats (CN 9401) and wooden furniture (CN 9403). Cattle hides and leather (CN 4101, 4104) were in scope until the Commission's delegated act of 13 July 2026 removed them.
Not everything is in scope. Cardboard boxes (HS 4819) and wooden pallets (HS 4415) used only to protect or carry the product are excluded. So is material that has reached the end of its life, such as timber from a dismantled building. Virgin by-products are not excluded: sawdust from a sawmill that goes into particleboard is fully covered.
Operator or trader: your role under EUDR
Terms to know · Operator
The entity that first places a relevant commodity or product on the EU market or exports it. Operators bear the heaviest due diligence obligations under the EUDR.
Your duties depend on your role in each supply chain, not on your company as a whole. The same brand can be an operator for imported frames and a trader for boards bought from an EU mill. Operator or trader, SME or non-SME: the four combinations below carry four different sets of duties.
Per supply chain, and again whenever a supplier or a route changes.
Decide the company's size class, then follow each product to the point where it is first placed on the EU market. Whoever does that is the operator.
Company size figures, customs declarations naming the importer, and the supplier contracts that transfer ownership.
In practice
Importers (Operators)
Full due diligenceYou manufacture outside the EU and import into the EU.
- Collect all Phase 1 data
- Run risk assessment
- Submit the initial DDS
Non-SME Traders
Full due diligenceLarge retailers buying from EU importers.
- Verify supplier's due diligence
- Submit a new DDS referencing theirs
- Same obligations as operators
SME Operators
Simplified obligationsSmall EU furniture makers buying compliant materials.
- No repeat due diligence on compliant EU material
- Collect upstream DDS reference number
SME Traders
Record-keeping onlySmall retailers reselling within the EU.
- Keep buy/sell records for 5 years
- Retain DDS reference numbers
- No DDS submission required
Quantities, suppliers, country of production, Latin species names, harvest dates and plot-level geolocation.
Verify the data and assess risk. Where risk is not negligible, apply mitigation such as audits or additional evidence.
Submit the Annex II statement via TRACES NT, obtain the reference number and pass it downstream.
EUDR due diligence, step 1: information and plot-level traceability
Before a shipment is placed on the market, the operator holds the full chain for it. That means quantities, supplier details, country of production, species, harvest dates, legality documents and the geolocation of every plot the material came from.
Before placing on the market, exporting, or submitting the statement.
Ask tier 1 for the plot, and keep asking down the chain until a plot answers. The chain of custody must be unbroken from the forest to the finished product.
- Chain of custody: supplier and buyer names, email and postal addresses for every handover from the forest plot to the finished product.
- Legality permits: proof the harvest was legal where it happened: land tax receipts, harvest permits, concession maps, or contracts with local communities.
- Risk context: corruption indices, satellite imagery such as Copernicus, and third-party audits or certifications, ready for the risk assessment.
- Harvest period: the felling date, or the date range.
- Geolocation: coordinates for each plot. A single point for plots under 4 hectares; a full polygon above 4 hectares.
- Species: the common name and the Latin binomial for every wood component.
In practice
With the chain and the legality in hand, two rules remain: the geolocation format and the composite-material cases.
Geolocation precision
Composite products (plywood, MDF)
Chasing suppliers for polygons, permits and Latin names by email does not hold across a season. In Tappr, Trace sends each supplier a link for the styles they make and reads the documents they attach, so your team approves instead of chases.
EUDR due diligence, step 2: risk assessment and mitigation
The test is absolute. You must show that the risk of deforestation or illegality in your product is negligible. If it is not negligible after mitigation, the product cannot be placed on the EU market.
Operators verify the step-1 data and assess the risk against the criteria in Article 10(2). Where the risk is not negligible, they mitigate it: an independent audit, more documents, or another source.
Before submitting the statement and placing the product on the market.
Write a risk assessment per supplier, and keep it. The assessment sets your collected data against country risk, supply chain complexity and the presence of indigenous peoples.
The step-1 package: satellite imagery, corruption indices, legality evidence and third-party audit reports.
How to perform due diligence to make your risk negligible
If all the legality and forest management checks out, is the risk negligible?
No. Legality is one of three conditions. A harvest can be fully legal and still fail if the plot was natural forest on 31 December 2020 and was converted afterwards.
Scenario A: The clear plantation
A tidy plantation with a replanting plan looks like negligible risk. It is not, until the satellite record says so. If the plot was natural forest on 31 December 2020 and was cleared to plant, the product is banned however well the plantation runs today.
Scenario B: The complex natural forest (e.g., Indonesia)
Teak from a natural forest in Indonesia, with a village nearby, carries a higher starting risk and needs three specific checks:
- Deforestation: do satellite images, such as the EU Observatory or Copernicus, show forest cover loss at the plot edges?
- Indigenous and local rights: Article 10(2) requires checking for indigenous peoples and that free, prior and informed consent (FPIC) was respected. Any land dispute with the village counts.
- Forest management: how the forest is run and how high the corruption index is. FSC, PEFC or SVLK certification does not replace due diligence; it is evidence that helps bring the risk to negligible.
The due diligence statement: filed in TRACES NT before the goods move
Before the product is placed on the market, the operator submits a due diligence statement to the EU information system, TRACES NT, declaring no or negligible risk.
Before the product is placed on the market, made available, or exported.
Submit the Annex II template through TRACES NT, take the reference number, and pass it to your buyers.
Your EORI number, the CN codes, product descriptions, Latin species names and the plot coordinates.
In practice
The statement itself is small: EORI, CN codes, species, geolocations. You do not upload the supply chain history or the permits. An operator can reference an upstream statement instead of re-entering its data, and can export a version that hides plot coordinates from downstream buyers. Authorities message you through the same system.
The statement is the easy part. Behind it the operator must have done full due diligence, and when the authority audits, a reference number is not an answer. The chain, the satellite check, the permits and the assessment have to be on file for that shipment.
Record-keeping: five years of records, one annual report
Every due diligence record is kept for five years. Non-SME operators also publish a yearly report on their due diligence system.
Ongoing, post-submission.
Archive every statement reference, supplier exchange and risk assessment where an auditor can find it. Publish the yearly summary of risk conclusions and stakeholder consultation.
System logs, the public report, and a five-year archive.
EUDR timeline and application dates
The cut-off date is fixed. The application dates have moved twice and were last amended by Regulation (EU) 2024/3234 and the December 2025 amendment; the table shows the dates now in force.
Cut-off date (confirmed)
The strict cut-off date. Commodities produced on land deforested after this date are permanently banned.
Entry into force (confirmed)
Products harvested or produced before this date are generally exempt from the EUDR.
Application for non-SMEs (confirmed)
Entry into application for large and medium enterprises (non-SMEs).
Application for SMEs (confirmed)
Deferred entry into application for micro and small enterprises (SMEs). Note: SMEs handling timber already covered by the older EUTR must still comply by 30 December 2026.
EUDR compliance: what to have in place before 30 December 2026
Classify your products against Annex I CN codes
Find every product with wood or natural rubber in it and map it to its Annex I CN code.
Determine your legal role per supply chain
Decide, per product line, whether you are an operator or a trader, and whether SME rules apply.
Build a full chain of custody
Name every actor from plot to product, with addresses, felling dates and permits from tier 1 down.
Collect geolocation and species data
Collect a point or polygon for every plot, and the Latin name of every wood species, composites included.
Run a formal risk assessment
Set supplier data against satellite imagery, country benchmarks and corruption indices. Mitigate anything above negligible.
Submit DDS via TRACES NT
File the Annex II statement with EORI, CN codes, species and plots. Pass the reference number down the chain.
Establish 5-year record-keeping
Keep every statement, assessment and supplier exchange for five years where an auditor can reach it.
Set up annual reporting (non-SMEs)
If you are a large company, prepare the yearly public report on your due diligence system and its findings.
EUDR questions, answered
Is leather still covered by EUDR?
When does EUDR apply, after the delay?
Are paper manuals inside furniture boxes in scope?
Does EUDR apply to products made before 29 June 2023 but sold in 2026?
We buy MDF from an EU supplier. Do we have to do the mapping?
Official sources
- Regulation (EU) 2023/1115: Core EUDR text outlining operator/trader obligations, definitions, and Annex I commodity codes
- Regulation (EU) 2024/3234: Amending regulation with the first delay; the dates now in force are 30 December 2026 and 30 June 2027
- Commission EUDR guidance (April 2025): Clarifications on composite products, agricultural use, waste exemptions, and the role of certifications
- Commission benchmarking methodology (SWD 2025/129): Framework for determining low, standard, and high-risk countries
- EU information system API guidelines (March 2025): Technical specifications for TRACES NT, DDS submissions, and data privacy features