Does the EUDR apply to your business? Start at the beginning
Do you work with EUDR products? Find out which rules may apply to your business and what you need to put in place.
Not every business has the same obligations
The EUDR does not impose the same requirements on every business. Which obligations apply depends on your products, activities, role in the supply chain and business size. Together, these factors determine which rules and obligations are relevant to your business.
In this article
Does the EUDR apply to your products and activities?
The fact that a product contains cocoa, coffee, wood or another EUDR commodity does not automatically mean that the product falls within the scope of the EUDR. And even if a product does fall within scope, the obligations are not the same for every business.
You therefore need to establish which products are involved, what your business does with those products, what role you have in the supply chain and which business category applies. Together, these factors determine which obligations apply to your business. This assessment is relevant now, even if your EUDR obligations do not take effect until later.
Which products fall under the EUDR?
The EU Deforestation Regulation (EUDR) aims to prevent certain products associated with deforestation or forest degradation from being placed on the European market or exported from the EU.
The EUDR covers seven commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood.
However, not every product containing one of these commodities automatically falls under the EUDR. You need to check Annex I to the EUDR. lists the relevant products and links them to official Combined Nomenclature (CN) codes.
Chocolate, for example, may fall under the EUDR, while a chocolate biscuit does not automatically fall within scope simply because it contains cocoa. The specific product and its corresponding CN code are decisive.
Please note: the EUDR was amended at the end of 2025. The list of products in Annex I is also changing. On 13 July 2026, the European Commission adopted an amendment to Annex I. Always check the current product list rather than relying on older EUDR overviews.
What role does your business have and what do you need to do?
If a product falls under the EUDR, the next question is: what does your business do with that product?
Operator
An undertaking that places a relevant product on the EU market for the first time or exports it and does not qualify as a downstream operator. This could, for example, be an undertaking that imports a relevant product from outside the EU.
In broad terms: carry out due diligence before placing the product on the market or exporting it. If no risk or only a negligible risk of non-compliance has been identified, the operator submits a due diligence statement (DDS).
Micro or small primary operator
A natural person or micro or small undertaking established in a low-risk country that produces the relevant commodity there itself and places the relevant product on the EU market or exports it. In broad terms: this operator also carries out due diligence, but a simplified regime applies to this category. In principle, a one-off simplified declaration is submitted instead of separate DDSs. If the required information is already available in a legally established system or database, an exemption from submitting the declaration itself may apply under the conditions set out in the EUDR.
SME downstream operator or trader
An undertaking that qualifies as an SME and further processes or resells relevant products after those products have already been covered earlier in the supply chain by a DDS or simplified declaration.
In broad terms: no separate due diligence and no DDS. The undertaking must, however, collect the prescribed information about suppliers and customers and retain it for at least five years. If it receives information indicating that a product it has already placed or made available on the market may not comply with the EUDR, it must inform the competent authorities and the customers to whom it supplied the product.
Non-SME downstream operator or trader
An undertaking that does not qualify as an SME and further processes or resells relevant products after those products have already been covered earlier in the supply chain by a DDS or simplified declaration.
In broad terms: no separate due diligence and no DDS. The undertaking must, however, collect the prescribed information about suppliers and customers and retain it for at least five years. In addition, it must register in the EUDR Information System before placing or making relevant products available on the market or exporting them.
If the undertaking receives information about possible non-compliance, notification obligations apply. Where there are substantiated concerns, it must also verify, before placing or making the products available on the market or exporting them, that due diligence has been exercised and that no risk or only a negligible risk has been identified.
A single business can have different roles for different products. A wholesaler, for example, may be a trader for products it purchases within the EU but an operator for products it imports itself.
How do you know if you are the first party further down the supply chain?
If your supplier provides you with a DDS reference number or the identification number of a simplified declaration, the European Commission states that you may assume that your supplier is the upstream operator or micro or small primary operator and that you are the first downstream party.
You do not need to determine this yourself or ask your supplier for these numbers. The upstream party must provide them to the first customer further down the supply chain. The first downstream party must retain the reference or identification numbers received for at least five years.
Does the size of your business make a difference?
Yes. The size of your business can determine which obligations apply and when.
A business does not automatically fall outside the EUDR simply because it considers itself small. Nor is every small business a micro or small primary operator. Specific conditions apply to this particular category, including conditions relating to the size of the business, production of the relevant commodity and the country in which the business is established.
The relevant business category must therefore be determined using the criteria set out in the legislation.
When will the EUDR apply to your business?
The main EUDR obligations apply, as a general rule, from 30 December 2026. For operators that were established by 31 December 2024 as a natural person or as a micro or small undertaking, a later date applies to most products: 30 June 2027. This later date does not apply to products that were already covered by the previous EU Timber Regulation.
Even if 30 June 2027 applies to your business, you need to establish now whether the EUDR applies to you and what you need to prepare. For businesses subject to the 30 December 2026 date, preparation is now urgent.
What requirements must a product meet?
A relevant product may only be placed or made available on the market or exported if it:
is deforestation-free;
has been produced in accordance with the relevant legislation of the country of production;
is covered by a due diligence statement (DDS) or, where required by the EUDR, a simplified declaration.
The EUDR is therefore not only about deforestation. Relevant legislation in the country of production includes, among other things, rules on land-use rights, environmental protection, third-party rights, labour rights, human rights, taxation, anti-corruption, trade and customs.
Simply knowing where a product comes from is therefore not enough.
What does this mean for an operator?
If your business is an operator for a particular product, it must in principle assess whether the product meets these requirements before placing it on the market or exporting it. The EUDR requires a due diligence procedure for this purpose.
Collect information – Gather the necessary information about the product, its origin, production and supply chain.
Assess risk – Check and assess this information. Is there a risk that the product does not comply with the EUDR?
Mitigate risk – If the risk assessment shows more than a negligible risk, take additional measures before placing the product on the market or exporting it.
For products from low-risk countries, a simplified due diligence procedure may apply under the conditions set out in the EUDR. In that case, risk assessment and risk mitigation are in principle not required unless relevant information indicates a risk.
What information does an operator need?
The EUDR requires, among other things, information about:
the product and quantity;
the country of production;
suppliers and customers;
the location of the plots of land where production took place;
the deforestation-free character of the product;
compliance with the relevant legislation of the country of production.
The operator must check and assess this information. Simply collecting data is therefore not sufficient.
When do processes and systems come into play?
Processes and software can support the collection, checking and recording of EUDR information. But only once it is clear which obligations apply to your business can you determine what support is actually needed. A system supports implementation. It does not determine which EUDR rules apply to your business and products.
What should every business do now?
Determine now whether the EUDR applies to your business, even if your obligations do not take effect until later.
Which of our products could fall under the EUDR?
What do we do with these products and what role do we have?
From what date do which obligations apply to our business?
What information, processes, responsibilities and systems do we need?
What does the EUDR mean for your business?
DUFINCO helps organisations determine which EUDR rules apply to their products and activities and translate those requirements into workable implementation.
Would you like to know what the EUDR means for your business? Contact DUFINCO at info@dufinco.nl or call +31 6 512 47 217.
This article is based on the EUDR and the European guidance available as at 16 September 2026.
