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EU Deforestation Regulation · checked 23 October 2026

EUDR applies on 30 December 2026. Every lot needs a plot behind it.

Regulation (EU) 2023/1115 bans placing cattle, cocoa, coffee, oil palm, rubber, soya and wood products on the EU market, or exporting them, unless they are deforestation-free, legally produced and covered by a due diligence statement. The dates are fixed and the Commission has ruled out a third delay.

  • EUDR · THE DATES THAT APPLY
  • 31 Dec 2020cut-off date
  • 30 Dec 2026large & medium
  • 30 Jun 2027micro & small
  • 30 Dec 2027products added in Sept 2026
  • Reg. (EU) 2025/2650fixed in law
Checked 23 October 2026

Where it stands.

Each line names the source it was checked against.

Large & medium
From 30 December 2026, for operators and traders. Micro and small operators already covered by the old EU Timber Regulation come in on the same date. Reg. (EU) 2025/2650
Micro & small
From 30 June 2027 for every other micro and small operator. Reg. (EU) 2025/2650
Who files
Only the operator who first places a product on the EU market, or exports it, files the due diligence statement. Downstream operators and traders keep the reference number they receive and pass it on. Traders that are not SMEs still register in the EU information system. Reg. (EU) 2025/2650; Commission Access2Markets
Delays
The Commission's May 2026 simplification review cut the paperwork and kept the dates. Commission review, May 2026
Product list
Delegated Regulation (EU) 2026/2102, in force 18 September 2026, removed some items (certain bovine hides and leather, retreaded tyres, soybeans for sowing, some vulcanised rubber goods) and added others (soluble coffee, more palm-oil derivatives). Added products are covered from 30 December 2027. Check your HS codes against the current Annex I. Delegated Reg. (EU) 2026/2102
Penalties
Member states set them. The maximum fine must be at least 4% of the company's total annual EU turnover, alongside confiscation of the goods and the revenue. Reg. (EU) 2023/1115, Art. 25
The rule

What has to be true for each lot.

  • Deforestation-free

    Produced on land that was not deforested after 31 December 2020. Wood must also come from forests not degraded after that date.

  • Legally produced

    Made in line with the laws of the country of production: land use, labour, environment, tax, trade and the rights of indigenous peoples.

  • Geolocated to the plot

    The coordinates of every plot the commodity came from. A single point for small plots, a polygon for plots over 4 hectares. A region or a cooperative is not enough.

  • Covered by a statement

    A due diligence statement filed in the EU information system before the goods are placed on the market or exported. Its reference number follows the goods.

Where Aeroz fits

How Aeroz carries the plot to the border.

  • Plot to lot

    Each lot is bound to the geolocation of the plots it came from, at the point it is first aggregated.

  • Through the pooling

    Every handoff is a signed, timestamped event, so the link from mapped plots to the shipped lot survives buying stations, blending and export.

  • The statement travels

    The due diligence statement reference rides with the lot through every handoff, which is what downstream operators and traders must keep.

Questions

EUDR, answered.

When does EUDR apply?

From 30 December 2026 for large and medium operators and traders, and from 30 June 2027 for micro and small operators, except those with timber products already under the old EU Timber Regulation, who start on 30 December 2026. The dates were set by Regulation (EU) 2025/2650, and the Commission's May 2026 review confirmed them.

Which products are covered?

Cattle, cocoa, coffee, oil palm, rubber, soya and wood, and the products made from them listed in Annex I. The list was amended by Delegated Regulation (EU) 2026/2102 in September 2026, so check your HS codes against the current version.

Do I have to file a due diligence statement?

Only if you are the operator who first places the product on the EU market or exports it. Downstream operators and traders keep and pass on the reference number of the statement they received.

Does certification satisfy EUDR?

Not on its own. Mass-balance certification shows a volume was bought into a certified pool; EUDR asks which plot this consignment came from. Certification can be evidence inside your due diligence, not a replacement for it.

Does EUDR require a chip or RFID?

No. The regulation asks for geolocation, a deforestation and legality assessment and a filed statement. How you carry that data through the chain is your choice.

Which countries are low risk under EUDR?

Commission Implementing Regulation (EU) 2025/1093 lists the low-risk countries, among them every EU member state, the United States, China, India, Vietnam and Ghana. Only Belarus, Myanmar, North Korea and Russia are high risk; every other country, including Brazil, Indonesia and Côte d'Ivoire, is standard risk. Low risk allows simplified due diligence under Article 13: you still collect plot geolocation, but skip the full risk assessment and mitigation, as long as everything in the product comes from low-risk countries.

Sources: Regulation (EU) 2023/1115 · Regulation (EU) 2025/2650 · Implementing Regulation (EU) 2025/1093: country risk list · Commission Access2Markets: delay until December 2026 · IHK: delegated act on the EUDR product scope. Checked 23 October 2026. Not legal advice.

Key facts · EUDR

EUDR, Regulation (EU) 2023/1115, applies from 30 December 2026 for large and medium companies and from 30 June 2027 for micro and small ones, except timber already under the old EU Timber Regulation (30 December 2026). The cut-off date is 31 December 2020.

Commodities
7 · Annex I
Plot data
point or polygon
Statement
first placer files
Max fine
≥ 4% EU turnover