- Regulatory Guide
EU Deforestation Regulation (EUDR) 2023/1115 — Compliance Primer
Last reviewed: August 2026 · PassoNext Team
The EU Deforestation Regulation (EUDR), Regulation (EU) 2023/1115, prohibits placing seven key commodities—cattle, cocoa, coffee, oil palm, rubber, soy, and wood—or their derivative goods onto the EU market or exporting them from it unless they are verified as deforestation-free (sourced from land cleared of no forest after 31 December 2020), legally harvested in their country of origin, and backed by an official due diligence statement including GPS plot-level geolocation data. Under amending Regulation (EU) 2025/2650, compliance obligations apply to large and medium operators starting 30 December 2026, while micro and small enterprises transition on 30 June 2027.
- Regulates seven core raw materials—cattle, cocoa, coffee, oil palm, rubber, soy, and timber—alongside downstream derivatives like footwear leather, finished chocolate, wooden furniture, paper goods, and vehicle tires.
- Requires goods to be certified deforestation-free (zero land clearing after 31 December 2020), legally harvested under local laws, and registered via formal due diligence filings.
- Mandates collecting exact GPS plot coordinates for every parcel of land where raw commodities were cultivated.
- Follows an updated compliance schedule: large and medium enterprises take on obligations on 30 December 2026, while qualifying micro and small businesses transition on 30 June 2027.
- Submissions run through the dedicated EU Information System (TRACES); the EUDR functions as a supply chain compliance framework rather than a Digital Product Passport system.
Regulatory Primer. Essential, source-verified facts on the EU Deforestation Regulation. Citations below link to official EUR-Lex documentation.
What the EUDR does
Regulation (EU) 2023/1115 (the EU Deforestation Regulation) restricts commercial operators from importing, selling, or exporting seven key raw materials—cattle, cocoa, coffee, oil palm, rubber, soy, and wood—as well as listed secondary derivatives across the EU border unless they prove the items cause no forest degradation, comply with local laws in the origin country, and carry verified due diligence statements. Enacted on 29 June 2023, the measure aims to prevent EU consumer markets from driving global deforestation and habitat loss.
Who is in scope, and when
Amending legislation under Regulation (EU) 2025/2650 updated the regulatory schedule: large and medium traders and operators face mandatory enforcement on 30 December 2026, while small and micro enterprises transition on 30 June 2027 (with micro and small timber operators already governed by EUTR rules aligning on 30 December 2026). The environmental baseline remains universal across all groups: commodities must be free of land clearing occurring after 31 December 2020. The regulation’s annex specifies the scope through Customs Combined Nomenclature (CN) codes, covering processed products such as footwear leather, retail chocolate, timber furniture, paper packaging, and rubber tires.
What due diligence requires
Commercial operators must collate all relevant documentation certifying that the raw materials were legally harvested without deforestation and include the coordinates of all land parcels used in the process. Companies must also carry out risk assessments and implement mitigation measures, while ensuring all formalities are completed and due diligence is filed in the central EU information system (TRACES). Although the EUDR is not a DPP, the requirements it imposes on land use at the farm and holding level are similar to the supplier checks required for the DPP for tires, furniture, and textiles.
What This Means For Your Business
The EUDR places the full burden of proof on commercial entities. Before bringing covered items into the EU, you must trace every constituent ingredient back to its exact plot of origin and prove that no forest conversion occurred on that land after 31 December 2020. For supply chains handling rubber, leather, paper, or packaging, this requires establishing plot-level GPS mapping and chain-of-custody tracking systems that previously did not exist.
Because regulatory scope depends entirely on tariff codes, items not traditionally linked to forest loss—such as printed promotional packaging, office furniture, or vehicle tires—can still trigger compliance obligations. Auditing your product portfolio against the regulation’s annex represents the essential starting point for assessing your operational exposure.
Action Steps
- Cross-reference your product list against EUDR commodity and CN codes to identify affected SKUs.
- Secure GPS plot geolocation data for every farm, plantation, or forest plot supplying covered inputs.
- Confirm legal harvesting practices in origin countries and assemble supporting compliance certificates.
- Develop an internal due diligence workflow and configure your system to lodge filings via the EU TRACES platform.
- Verify your legal compliance deadline—30 December 2026 for large/medium operators and EUTR timber SMEs, or 30 June 2027 for remaining micro and small businesses.
- What is a DPP?
- EU Battery Regulation
- ESPR 2024/1781
- EU Deforestation (EUDR)
- EU Packaging (PPWR)
- Mandatory Fields
- GS1 Digital Link
- EU Central Registry
- Registry Operator Guide
- Registry Regulation 2026/1778
- GDPR & DPPs
- REACH & SVHC
- Access Rights (PoLI)
- Compliance FAQ
- Deferred Data Points
- Delegated Acts Tracker
Frequently asked questions
What is the EU Deforestation Regulation (EUDR)?
The EUDR, Regulation (EU) 2023/1115, prohibits the placement on the EU market of seven commodities and derived products, and their export from the EU, unless they are deforestation-free, legal, and accompanied by a due diligence statement. It came into force on 29 June 2023 to protect the world’s forests from contributing to EU consumption.
Which commodities and products does EUDR cover?
The EUDR covers seven commodities: cattle, cocoa, coffee, oil palm, rubber, soy, and wood, and a list of derived products, such as leather, chocolate, coffee, palm-oil derivatives, furniture, paper, and rubber tyres. The determination of whether a product falls under the scope of the Regulation depends on the commodity codes specified in the Regulation’s annex and not on the percentage content of a particular commodity.
When does EUDR apply?
With the adoption of the amending regulation (EU) 2025/2650 in December 2025, EUDR applies to large operators and traders from 30 December 2025, and to micro and small operators and traders from 30 June 2026. The cut-off date for the regulation is 31 December 2020, meaning that commodities placed on the market should not have contributed to deforestation and illegal logging.
What does EUDR due diligence entail?
The operator must gather information to demonstrate that each particular commodity is not associated with any deforestation and is produced legally. This includes the specific location of the plots where the commodity was grown. The operator must assess and address risks and provide a due diligence statement, available to the competent authorities, which will be stored in the EU database TRACES. EUDR is a due diligence and customs control regulation; it is not a Digital Product Passport (DPP), although the requirement to trace products at the level of individual plots is similar to what DPPs for downstream products will entail.
Is EUDR a Digital Product Passport regulation?
EUDR is not a DPP regulation; it has its own set of requirements and databases (TRACES). However, the traceability of downstream products, such as rubber, leather, paper, and packaging, back to the original plot, required under EUDR, is similar to the requirements that DPPs for tyres, furniture, and textiles might include.
Ready to start your product passport?
Start free. No credit card required. Your first 10 passports stay free, even after the trial ends.
