Everything you need to know about the EU Deforestation Regulation — scope, timeline, the seven regulated commodities, penalties of up to 4% of turnover, and a step-by-step path to compliance before the December 2026 deadline.
Between 1990 and 2020, the world lost approximately 420 million hectares of forest — an area larger than the entire European Union. Deforestation and forest degradation are the second-largest source of greenhouse gas emissions after fossil fuels, and they destroy biodiversity at an alarming rate. Tropical forests in the Amazon, Congo Basin, and Southeast Asia are under particular pressure from agricultural expansion.
The European Union is a major consumer of commodities linked to deforestation. Research by the European Commission estimates that EU consumption drives roughly 10% of global deforestation, primarily through imports of agricultural and forestry products. Palm oil, soya, and cattle products account for the largest share, but coffee, cocoa, rubber, and wood also contribute significantly.
In response, the EU adopted Regulation (EU) 2023/1115 — the EU Deforestation Regulation, commonly known as the EUDR. It replaces the older EU Timber Regulation (EUTR) and goes far beyond it. Where the EUTR only covered wood and wood products, the EUDR extends mandatory due diligence to seven commodity groups and all their derived products. The goal is straightforward: no product placed on the EU market should contribute to deforestation or forest degradation anywhere in the world.
The EUDR covers seven commodity groups and a wide range of derived products listed in Annex I of the regulation. If your product contains, was fed with, or was made using any of these commodities, it likely falls within scope.
Palm oil is the world's most widely used vegetable oil, found in food products, cosmetics, cleaning agents, and biofuels. Indonesia and Malaysia produce over 80% of global supply. Oil palm plantations are a leading driver of tropical deforestation in Southeast Asia, and increasingly in West Africa and Latin America. The EUDR covers crude palm oil, refined palm oil, palm kernel oil, and derived products such as oleochemicals and biodiesel feedstocks.
Soya is the second-largest driver of deforestation globally, primarily in Brazil, Argentina, and Paraguay. Most soya is used as animal feed in the EU livestock industry, but it also appears in processed foods, lecithin, and industrial products. The regulation covers soybeans, soya meal, soya oil, and products containing soya-derived ingredients.
Cattle ranching is the single largest driver of deforestation in the Amazon. The EUDR covers live cattle, beef, leather, tallow, and other bovine products. This means EU importers of leather goods, footwear, and automotive interiors must also trace their supply chains back to the production plot.
Coffee production drives approximately 7% of tropical deforestation. Brazil, Vietnam, Colombia, and Ethiopia are the largest producers. The regulation covers green coffee beans, roasted coffee, instant coffee, and coffee extracts. EU coffee importers — from specialty roasters to large trading houses — must verify that their sourcing plots have not been deforested since the cutoff date.
Cocoa farming is a major deforestation driver in West Africa, particularly in Côte d'Ivoire and Ghana, which together produce about 60% of the world's cocoa. The EUDR covers cocoa beans, cocoa butter, cocoa powder, chocolate, and all products containing cocoa. The complex, multi-layered nature of cocoa supply chains — often involving smallholder farmers — makes traceability particularly challenging.
Wood and wood products were already regulated under the EUTR, but the EUDR significantly expands the scope. It now covers timber, plywood, paper, pulp, printed books, furniture, charcoal, and many more derived products. The regulation applies to both tropical and temperate wood, meaning EU domestic forestry operations are also in scope.
Natural rubber production is expanding rapidly in Southeast Asia and West Africa, often at the expense of tropical forests. The EUDR covers natural rubber latex, rubber sheets, tyres, and rubber-based industrial products. This brings automotive, manufacturing, and industrial supply chains into the regulation's scope for the first time.
Understanding the EUDR timeline is critical for planning your compliance programme. Here are the dates that matter:
The EUDR places obligations on two categories of businesses: operators (companies that first place regulated products on the EU market or export them) and traders (companies that make regulated products available on the market in the course of a commercial activity). Operators bear the heaviest obligations. Here is what they must do:
One of the most technically demanding aspects of the EUDR is the geolocation requirement. Article 9 requires operators to collect the geographic coordinates of all plots of land where the relevant commodity was produced. The EU has published detailed technical specifications (EUDR v1.5) for how this data must be formatted.
For companies with large supply chains spanning thousands of smallholder farms, collecting and validating this geolocation data is one of the biggest operational challenges of EUDR compliance. Many operators are turning to digital tools that accept multiple input formats (GeoJSON, KML, WKT, CSV) and automatically validate against the EUDR specification.
The European Commission will classify countries (or parts of countries) into three risk categories based on their rate of deforestation and forest degradation, governance indicators, and enforcement of relevant legislation. This benchmarking system directly affects the level of due diligence required:
As of early 2026, the Commission has not yet published the final country benchmarking list. Until it does, all countries of production are treated as standard risk, meaning full due diligence applies universally.
The EUDR establishes a robust enforcement framework with penalties that are designed to be "effective, proportionate, and dissuasive" (Article 25). Member States are responsible for setting specific penalty levels, but the regulation sets minimum requirements:
These penalties apply to both operators and traders. The severity of the penalty depends on factors including the gravity and duration of the infringement, the environmental impact, previous infringements, and the operator's cooperation with authorities.
Achieving EUDR compliance requires a structured approach. Here is a practical six-step framework that operators and traders can follow:
Review Annex I of Regulation (EU) 2023/1115 and check whether any of your products contain, are derived from, or were fed with any of the seven regulated commodities. Use the Combined Nomenclature (CN) codes listed in the Annex to match against your product portfolio. If in doubt, consult your customs declarations and HS code classifications.
Identify every supplier in your chain, from the point of production (farm, plantation, forest concession) through intermediaries to your EU entry point. Document the chain of custody for each product. For complex supply chains with multiple tiers, focus first on direct (Tier 1) suppliers and work backwards.
Request GPS coordinates or polygon boundaries from your suppliers for every plot of land where the commodity was produced. Validate the data against the EUDR v1.5 specification: WGS84 coordinates, 6 decimal places, GeoJSON format, and polygon boundaries for plots ≥4 hectares.
Use Copernicus Sentinel-2 satellite imagery (or equivalent) to compare the state of each production plot during the baseline period (around June–August 2020) with its current state. Look for changes in vegetation indices (NDVI, NDMI) that indicate forest loss or degradation. Classify each plot as low, medium, or high risk.
Evaluate the overall risk for each product and supply chain, considering country risk, supplier history, certification status, complexity of the chain, and any concerns raised by civil society or media. Where risk is not negligible, implement mitigation measures such as additional verification, independent audits, or supplier engagement programmes.
Once you have determined that the risk of non-compliance is negligible, prepare and submit your DDS through the EU TRACES NT system. The DDS must include all required information: product description, quantity, country of production, geolocation data, supplier details, and your risk assessment conclusion. Retain all records for at least 5 years.
The EU Deforestation Regulation represents the most ambitious attempt by any jurisdiction to break the link between commodity consumption and global deforestation. For EU importers, it means a fundamental shift in how supply chains are managed — from voluntary sustainability commitments to mandatory, verifiable due diligence backed by satellite evidence and enforceable penalties.
The December 2026 enforcement deadline is approaching. Companies that start preparing now — mapping supply chains, collecting geolocation data, and establishing satellite monitoring processes — will be in the strongest position when enforcement begins. Those that wait risk not only regulatory penalties but also disruption to their supply chains as the entire market adjusts to the new requirements.
The technology to comply exists today. Copernicus satellite data is freely available, geolocation validation tools are mature, and compliance platforms can automate much of the due diligence process. The question is not whether compliance is possible, but whether your organisation is ready.
See how Plotwiser's AI-powered solution handles your entire due diligence pipeline.
