PLMV-KB-019 · Regulation & Compliance · Reviewed 2026-10-16
EUDR: Deforestation Regulation and Product Traceability
The EU Deforestation Regulation (EUDR), Regulation (EU) 2023/1115, bans placing cattle, cocoa, coffee, oil palm, rubber, soya and wood products on the EU market unless they are deforestation-free, legally produced and covered by due diligence. After amendment by Regulation (EU) 2025/2650, it applies from 30 December 2026 for large and medium operators.
Key takeaways
- EUDR applies from 30 December 2026 for medium and large operators and from 30 June 2027 for micro and small operators.
- Products must trace back to plots of land with geolocation and be free of deforestation after 31 December 2020.
- The December 2025 amendment simplified duties for downstream operators and traders, and a July 2026 delegated act removed cattle leather and some rubber products from scope.
- Product data teams must link EUDR-relevant materials in the bill of materials to commodity codes, suppliers and due diligence statement references.
Why the EUDR dates moved twice
The EUDR entered into force on 29 June 2023 and was originally due to apply from 30 December 2024. Regulation (EU) 2024/3234 postponed application by one year. In December 2025, Regulation (EU) 2025/2650 postponed it again and simplified the obligations. The current dates are:
| Operator type | Application date |
|---|---|
| Medium and large operators and traders | 30 December 2026 |
| Micro and small operators | 30 June 2027 |
| Products added by the July 2026 scope delegated act | 30 December 2027 |
The amendment required a simplification review by 30 April 2026. The Commission published its report on 4 May 2026, concluded that the regulation would not be reopened and confirmed the dates above. At the latest update reviewed (October 2026), no further postponement had been proposed by the Commission.
Which products and commodities are covered?
The seven relevant commodities are cattle, cocoa, coffee, oil palm, rubber, soya and wood. Annex I lists the derived products by Combined Nomenclature code, including chocolate, furniture, paper, printed products, tyres and many wood-based goods. On 13 July 2026 the Commission adopted a delegated act (C(2026)4920) that adjusts the scope:
- Removed: cattle hides, skins and leather, retreaded tyres, vulcanised rubber products, conveyor and transmission belts, vehicle and aircraft seats, soya beans for sowing.
- Added: instant coffee, certain palm oil derivatives and frozen cattle tongues.
- Clarified as exempt: samples and test products, waste and second-hand products, and packaging used solely to support another product.
The delegated act was under scrutiny by Parliament and Council and was expected to take effect in December 2026.
What due diligence requires
Operators that first place relevant products on the EU market or export them must:
- Collect information: product description, quantity, country of production and geolocation of all plots of land where the commodity was produced (polygons for plots above four hectares, except cattle).
- Assess risk: deforestation after 31 December 2020, legality under the laws of the country of production, and country risk under the Commission benchmarking (low, standard or high).
- Mitigate risk: until it is none or negligible.
- Submit a due diligence statement: in the EU information system, whose rules are set in Implementing Regulation (EU) 2026/1565.
After the 2025 amendment, downstream operators and traders no longer submit their own statements. Non-SME downstream operators must register, keep supplier and customer records for five years and store the statement reference number when their direct supplier is the importer. Micro and small primary operators in low-risk countries can file a one-off simplified declaration.
Which data does PLM and PIM need?
EUDR is mainly a supply chain obligation, though product data determines which items are affected:
| Attribute | Level | Purpose |
|---|---|---|
| Commodity content flag (wood, rubber, cocoa and so on) | Material, part | Identifies affected items |
| CN code | Product, component | Scope check against Annex I |
| Material origin country | Material lot | Risk assessment |
| Supplier and producer identifiers | Supplier, lot | Traceability |
| Plot geolocation reference | Lot | Due diligence evidence |
| Due diligence statement reference number | Shipment, lot | Proof for downstream customers |
| Simplified declaration identifier | Supplier | Micro and small primary operators |
| Mixing and segregation method | Process | Chain of custody |
Formulation and specification tools for process industries and fashion and retail already hold ingredient and material origin data. Vendors such as TraceGains, Trace One Devex and Bamboo Rose support supplier and material data collection in these sectors. The reference numbers themselves usually sit in ERP or trade compliance systems, linked to lots. Composite products such as furniture, printed packaging or tyres need the commodity flag on each relevant component, because a single EUDR-relevant part brings the finished product into scope if its CN code is listed. Geolocation data is typically held in a dedicated traceability platform and referenced from product records. A clean bill of materials that flags commodity content at material level is the starting point, and product data quality checks on CN codes prevent scope errors. The scope changes of 2026 also mean that existing flags should be reviewed against the amended Annex I before the December application date.
Frequently asked questions
When does EUDR apply?
After Regulation (EU) 2025/2650, EUDR applies from 30 December 2026 to medium and large operators and traders, and from 30 June 2027 to micro and small operators. Products newly added by the July 2026 scope delegated act are covered from 30 December 2027. The Commission's May 2026 review confirmed these dates and stated that the regulation would not be reopened.
Is leather still covered by EUDR?
The delegated act adopted on 13 July 2026 removes cattle hides, skins and leather from the product scope, together with retreaded tyres, vulcanised rubber products and some other items. The act was subject to a two-month scrutiny period by Parliament and Council and was expected to take effect in December 2026. Cattle and beef products themselves remain covered.
Do downstream companies need their own due diligence statement?
Not any more. Since the 2025 amendment, downstream operators and traders do not submit their own due diligence statements. Non-SME downstream operators must register in the information system, keep supplier and customer records for five years and collect the statement reference number when their direct supplier is the operator that placed the product on the market. SMEs have lighter duties.
Sources
- Regulation (EU) 2023/1115 on deforestation-free products (EUR-Lex)
- Regulation (EU) 2025/2650 amending the EUDR (EUR-Lex)
- European Commission: Regulation on deforestation-free products
Reviewed 16 October 2026 by the PLM Vendors editorial team. Regulatory dates and vendor details change; check the sources for the latest position.