EUDR regulation: what the EU Deforestation Regulation asks of sellers

The EUDR is the EU Deforestation Regulation, Regulation (EU) 2023/1115. It covers seven commodities (cattle, cocoa, coffee, oil palm, rubber, soya and wood) and the products made from them that are listed in its Annex I, such as chocolate, coffee, tyres, wooden furniture and paper. Those products may only be placed on the EU market, sold or exported if they are deforestation-free (no deforestation after 31 December 2020), produced legally in the country of production, and covered by a due diligence statement.

The rules apply from 30 December 2026. Operators that were micro or small undertakings on 31 December 2024 start on 30 June 2027, except for timber products already covered by the old EU Timber Regulation. What you have to do depends on your role: the company that first places a product on the EU market (or imports it) runs due diligence and files the statement; shops and brands further down the chain keep supplier and customer records for five years. Either way, it starts with product data: the customs code decides whether a product is in scope.

Where the EUDR stands after two delays and the Annex I update

Much of what ranks for "EUDR" still shows the old dates or the old product list. The current text is the consolidated version of 18 September 2026, which includes both delays and the latest Annex I changes. The European Commission's EUDR page gives the same dates.

In its simplification review of 4 May 2026, the Commission said it did not consider it appropriate to propose further amendments to the basic legal text, so the dates above are the ones to plan for. One transition rule matters for furniture and timber sellers: timber products produced before 29 June 2023 and placed on the market from 30 December 2026 stay under the old EU Timber Regulation until 31 December 2029. The EU product compliance tracker and the compliance calendar list the EUDR dates next to the GPSR, packaging and battery rules.

Which products the EUDR covers: Annex I by commodity

The EUDR does not cover "anything containing wood". It covers the goods listed in Annex I, identified by their Combined Nomenclature (CN) code, the EU's 8-digit extension of the HS code. If a product's CN code is not in Annex I, the EUDR does not apply to it, even if it contains one of the seven commodities. Leather is the change most guides still miss: Delegated Regulation (EU) 2026/2102 took cattle hides and leather (headings 4101, 4104 and 4107) out of Annex I on 18 September 2026. Leather bags and shoes were never listed, and a leather sofa with a wooden frame is still in scope as an upholstered seat with a wooden frame (ex 9401 61 00).

The Annex also excludes some goods inside the listed codes. The ones that matter most for retail:

• Used and second-hand products under most wood and rubber entries, such as a second-hand wooden chair.
• Goods made entirely from waste, such as paper made only from recovered paper.
• Packaging that only supports, protects or carries another product. The cardboard box around a toaster is out; a wooden storage box sold as a product is in.
• Marketing material and correspondence that only accompanies another product.
• Bamboo, rattan and other woody materials under the wood entries, and synthetic rubber under the rubber entries.
• Samples of negligible value and goods sent for testing.

For a typical web shop the in-scope list is shorter than people fear and longer than they hope: chocolate and coffee, wooden furniture and seats, cutting boards and other wooden kitchenware, picture frames, paper notebooks and other articles of paper, new tyres and rubber gloves. Many wood and paper entries carry an "ex", so check the description, not only the code. Heading 4421, other articles of wood, is listed as "ex 4421" because used and second-hand items are excluded: a new wooden coat hanger is in scope, the same hanger sold second-hand is not.

Operator, downstream operator or trader: the role decides the work

The EUDR assigns duties by role, and one company can have different roles for different products. The definitions are in Article 2 of the Regulation; the Commission's EUDR FAQ (version 5, April 2026) applies them to online sales.

• Operator: places a relevant product on the EU market for the first time, or exports it. If a company outside the EU places a product on the market, the first person in the EU who makes it available counts as the operator. A web shop that imports wooden furniture from outside the EU is an operator for those products. Operators run due diligence, file a due diligence statement before placing the product, keep it for five years, and pass its reference number to the downstream operators and traders they supply.
• Downstream operator: places on the market products made from relevant products that are all already covered by a statement, for example a furniture maker using timber that an operator has already placed. Since the December 2025 amendment, downstream operators no longer file statements; they keep records.
• Trader: makes available products that someone else has already placed on the EU market. Most retailers that buy from EU wholesalers or brands are traders. Traders keep the name, postal address, email address and website of each supplier and business customer, plus the statement reference numbers when the supplier is an operator, for at least five years. Traders and downstream operators that are not SMEs also register in the EUDR Information System.

Selling online changes none of this. The Commission's FAQ says the EUDR applies to B2B and B2C supplies alike, that an online retailer which imports a product to fulfil an order is the operator, and that an online marketplace which only brings buyer and seller together has no EUDR duties (one that also sells or fulfils the order can take on a role). A consumer buying for private use is never the operator. Operators also do not have to pass reference numbers on to final consumers, so nothing has to appear on the product page.

What goes into a due diligence statement

Operators submit the statement electronically in the EUDR Information System, which the Commission launched on 4 December 2024. Annex II of the Regulation lists its content:

• Operator name and address, plus the EORI number for products entering or leaving the EU market.
• The HS code, a free-text description with the trade name, the full scientific name of the species where applicable, and the quantity (for imports and exports in kilograms of net mass, plus the supplementary unit where one applies).
• The country of production and the geolocation of every plot of land where the commodities were produced.
• A fixed declaration that due diligence was carried out and found no or only negligible risk, and a signature.

Geolocation has a precise meaning: latitude and longitude with at least six decimal digits, and a polygon outlining the plot for plots over four hectares (for cattle, the establishments where the animals were kept). Behind the statement sits the due diligence itself: collecting that information with evidence, a risk assessment that weighs the country's risk classification and the complexity of the supply chain, and risk mitigation where the risk is more than negligible. Operators review their risk assessments at least once a year.

The product data retailers and brands need per SKU

Most of the evidence (plots, coordinates, risk assessments) belongs to whoever runs due diligence, not to the product catalog. But every company in the chain needs a few product-level fields to know which SKUs are in scope, from when, and which supplier records to keep. A workable set of attributes:

• CN code (8 digits). The scope test. HS codes stop at 6 digits and some Annex I entries are 8-digit codes, such as 2101 11 00 for soluble coffee. Our guide to finding an HS code explains the structure.
• EUDR scope: in scope, partly in scope (an "ex" entry that needs a check of the description) or out of scope, with the date it applies (30 December 2026 or 30 December 2027).
• EUDR commodity: cattle, cocoa, coffee, oil palm, rubber, soya or wood.
• Country of production. Not the same as country of origin. Chocolate made in Belgium from cocoa grown in Ghana has Belgium as its customs origin and Ghana as the country of production of its cocoa.
• Wood species, common and scientific name, for wood products, because the statement asks for the full scientific name.
• Net mass in kilograms, which the statement uses as its quantity for imports and exports.
• Supplier reference: a link to the supplier record that holds name, postal address, email address and website.
• Second-hand flag, for shops that sell used goods, which are excluded under most entries.

Statement reference numbers are a different kind of data. They belong to a delivery or batch, not to a SKU, so they live best with purchase orders, invoices or delivery notes in your ERP or bookkeeping, where a competent authority can trace them for five years.

To fill the CN code across a catalog, WISEPIM's HS code task picks a code from the official EU Combined Nomenclature (8 digits) for each product you select, at one credit per product. You choose whether confident codes are saved right away or every code waits for your review. For a single product, the free HS code finder searches the same nomenclature.

Five catalog checks to run before the December 2026 start

1. Give every product an 8-digit CN code and compare it with Annex I. Mark "ex" matches for a manual check of the description.
2. Split the in-scope list by supplier. Products you import from outside the EU make you the operator; products bought from EU suppliers usually make you a trader.
3. Ask EU suppliers how they will pass on statement reference numbers, for example on the invoice or delivery note, and decide where you store them.
4. Add the missing attributes (commodity, country of production, wood species) as custom fields and make them required for in-scope products. A Quality Guard rule can flag products where a required field is empty.
5. Plan a second pass for 30 December 2027, when soluble coffee, palm-based soap and more palm oil derivatives come into scope, and take cattle hides and leather, which dropped out in September 2026, off your in-scope list.

Penalties for placing non-compliant products

Member States set the penalties, but Article 25 fixes the floor. For a legal person the maximum fine must be at least 4% of its total annual Union-wide turnover in the financial year before the fining decision, and the penalties include confiscating the products and the revenue from transactions with them. Competent authorities choose whom to check on a risk basis, using the data in the Information System.

WISEPIM does not file due diligence statements or hold plot geolocation; that stays with the operator and its systems. It keeps the product side in order: CN codes through the HS code task, EUDR attributes such as commodity and country of production as custom fields, and quality rules that show which in-scope products still miss them.