# EUDR Reference, Verified Facts, Tables & Sources Companion to `SKILL.md`. Regulation (EU) 2023/1115 (EUDR), consolidated EUR-Lex text applicable from 26 December 2025 (incorporates amending Regulations (EU) 2024/3234 and (EU) 2025/2650). Last reviewed against sources: 15 June 2026. Facts are tagged **[LAW]** (in force / published in the Official Journal) or **[PROPOSED]** (not yet adopted). `// VERIFY` marks anything moving as of mid-2026. --- ## 1. What the EUDR is - Full title: Regulation (EU) 2023/1115 of 31 May 2023 on the making available on the Union market and the export from the Union of certain commodities and products associated with deforestation and forest degradation. Entered into force 29 June 2023. **[LAW]** - Replaces and repeals the **EU Timber Regulation (EUTR), Reg (EU) No 995/2010**. Broader: adds six commodities beyond wood and adds a deforestation-free test on top of legality. - **Goal:** ensure commodities consumed in or exported from the EU are deforestation-free and legally produced. Flagship measure of the European Green Deal. Legal basis Art. 192(1) TFEU. - **Cut-off date: 31 December 2020** (Art. 2(13)). Goods are deforestation-free only if the source land was not deforested after this date; for wood, also no forest degradation after this date. ## 2. The dual test + DDS (Article 3) A relevant product may be placed/made available/exported only if it is: 1. **deforestation-free**; 2. **produced in accordance with the relevant legislation of the country of production**; and 3. **covered by a due diligence statement (DDS)**. The "legal" limb covers: land-use rights; environmental protection; forest rules; third parties' rights; labour rights; human rights under international law; Free, Prior and Informed Consent (FPIC); and tax, anti-corruption, trade and customs rules. ## 3. Deadlines: VERIFIED CURRENT (mid-June 2026) | Milestone | Date | Status | |---|---|---| | Regulation adopted | 31 May 2023 | [LAW] | | Entry into force | 29 June 2023 | [LAW] | | Original application (large) | 30 Dec 2024 | superseded | | First delay, Reg (EU) 2024/3234 | large → 30 Dec 2025; SME → 30 Jun 2026 | superseded | | Second delay, Reg (EU) 2025/2650 (OJ 23 Dec 2025) | +1 further year | [LAW] | | **Application, large & medium operators/traders** | **30 December 2026** | **[LAW]** | | **Application, micro & small enterprises + natural persons** (established as such by 31 Dec 2024) | **30 June 2027** | **[LAW]** | | Commission simplification review report | 4 May 2026 | [LAW] (report) | | Draft Delegated Act (Annex I scope) consultation close | 1 June 2026 | [PROPOSED] | `// VERIFY` **No third delay is in force.** As of mid-June 2026, web sources confirm 30 Dec 2026 / 30 Jun 2027 still hold. The Commission has stated the core Regulation will not be reopened. Treat any "further delay" as unverified unless backed by a new OJ publication. A micro/small enterprise created **after** 31 December 2024 does not get the 30 June 2027 grace and follows 30 December 2026. ## 4. Roles (who does what) | Role | Definition | Key duty | |---|---|---| | **Operator** | First places relevant products on the EU market, or exports them (Art. 2(15)). | Full 3-step due diligence; **files the DDS**. | | **Trader** | Anyone else in the EU chain who makes products available but did not first place them (Art. 2(17)). | SME traders: collect + pass on reference numbers, keep records 5 yrs. Large traders: operator-like duties. | | **Downstream operator** | Added by Reg (EU) 2025/2650: places/exports products **made from inputs already covered by a DDS**. | Does **not** file a new DDS; keeps supplier names, addresses, DDS reference numbers (5 yrs) and passes them on. | Non-EU suppliers are not directly regulated but are pulled in contractually: the EU operator must obtain geolocation, legality and deforestation-free evidence from them. ## 5. Company-size thresholds (EU Directive 2013/34/EU) A company is in a class if it does not exceed at least two of the three limits. | Size | Staff | Balance sheet | Net turnover | |---|---|---|---| | Micro | < 10 | ≤ €0.45m | ≤ €0.9m | | Small | < 50 | ≤ €5m | ≤ €10m | | Medium | < 250 | ≤ €25m | ≤ €50m | | Large | ≥ 250 | > €25m | > €50m | `// VERIFY` Thresholds were uplifted by Delegated Directive (EU) 2023/2775; confirm the exact figures your member state applies. For EUDR deadlines, only the micro/small vs medium/large split matters. ## 6. The 3-step due diligence **Step 1, Collect information (Art. 9).** Keep for 5 years: product description, CN/HS code, quantity; country (and region) of production; **geolocation of all plots** (lat/long WGS84 to ≥ 6 decimals; **polygon for any plot > 4 ha**) plus production date/range; supplier and buyer name/address/contact; evidence the goods are deforestation-free and legally produced. **Step 2, Assess risk (Art. 10).** Against: country/region benchmark tier; presence of forests and indigenous peoples; complexity and length of the chain; risk of mixing with unknown-origin material; prevalence of deforestation; corruption; substantiated third-party concerns. **Step 3, Mitigate risk (Art. 11).** Where risk is more than negligible, take measures (extra information, independent audits/surveys, supplier capacity-building) until risk is **negligible**, before placing the goods. **DDS.** Submitted electronically in the EU Information System (Art. 33 / TRACES) before placing/exporting. Annex II contents include operator identity, HS code, description, quantity, country of production, geolocation coordinates/polygons, and the due-diligence declaration. System issues a **reference number** + **verification number**; pass the reference number down the chain (Art. 4(7)). ## 7. Country benchmarking (Article 29; Implementing Reg (EU) 2025/1093, 22 May 2025) Three tiers: low / standard / high. Until classified, a country defaults to **standard**. - **High risk, only 4:** Belarus, Myanmar, North Korea, Russia. Full due diligence + enhanced scrutiny. - **Low risk, ~140:** incl. all EU states, UK, US, Canada, China, Japan, Australia, South Africa, India, Vietnam, Thailand, Ghana. **Simplified** due diligence (collect Step-1 info, confirm negligible risk and no circumvention; full risk assessment + mitigation not required). - **Standard risk, the residual default:** incl. Brazil, Indonesia, Malaysia, Côte d'Ivoire. Full due diligence. **Do not infer a tier from production volume.** The list is under review in 2026; confirm against the official source. The European Parliament objected to aspects of the methodology in 2025, but the adopted list (2025/1093) stands. ### Common origins (curated, confirm against the official list) | Country | Tier | Note | |---|---|---| | Belarus, Myanmar, North Korea, Russia | high | the only four high-risk | | All 27 EU member states | low | | | United Kingdom, Norway, Switzerland, Iceland | low | | | United States, Canada, Chile, Uruguay | low | | | China, Japan, Australia, New Zealand | low | China is a common wood processing hub, trace to country of harvest | | India | low | major coffee/rubber producer, still low risk | | Vietnam | low | major coffee/rubber/wood producer, still low risk | | Thailand | low | major rubber producer, still low risk | | Ghana | low | major cocoa producer, still low risk | | South Africa | low | | | Brazil | standard | soya, cattle, coffee | | Indonesia | standard | oil palm, rubber, cocoa | | Malaysia | standard | oil palm, rubber | | Côte d'Ivoire | standard | cocoa, rubber | | Argentina, Paraguay | standard | soya, cattle | | Colombia, Ecuador, Peru | standard | coffee, cocoa | | Nigeria, Cameroon | standard | cocoa | ## 8. Annex I scope by commodity (illustrative; confirm by exact CN/HS code) Annex I lists relevant products by **CN/HS (Combined Nomenclature) code**. Below is a non-exhaustive summary; the customs code on the import/export paperwork governs scope. | Commodity | Key derived / relevant products (CN/HS families) | |---|---| | **Cattle** | Live cattle (0102); bovine meat fresh/chilled/frozen (0201, 0202); edible offal (0206); raw hides & skins (ex 4101); tanned/crust leather (ex 4104); prepared leather (ex 4107) | | **Cocoa** | Cocoa beans, paste, butter/fat/oil, powder, chocolate (1801-1806) | | **Coffee** | Coffee, roasted or not, decaf or not (0901); extracts/essences where listed | | **Oil palm** | Palm oil & fractions (1511); palm kernels (1207 99); palm-based derivatives e.g. glycerol/oleochemicals (1513, 2306, 2905, 3823) | | **Rubber** | Natural rubber (4001); new pneumatic tyres (4011); some other rubber articles where listed. **Synthetic rubber not covered.** | | **Soya** | Soya beans (1201); flour/meal (1208); soya-bean oil (1507); oilcake/residues (2304) | | **Wood** | Fuel wood, logs, sawn wood, panels (Ch. 44); pulp & paper (Ch. 47, 48, excl. bamboo and recovered/recycled); wooden furniture (parts of 9401, 9403); prefabricated buildings of wood (9406). **Printed books removed from scope** (Dec 2024 amendment). | `// VERIFY` **Proposed scope change, draft Delegated Act, 4 May 2026, NOT yet law.** Would **remove** cattle hides/skins/leather (ex 4101, 4104, 4107), retreaded tyres, and waste/used/second-hand products/samples; would **add** soluble (instant) coffee, certain palm-oil derivatives (e.g. palm-oil soap), and frozen cattle tongues. Consultation closed 1 June 2026; in Parliament/Council scrutiny (≈60 days) as of mid-June 2026; expected to enter force around summer 2026 if adopted. **Until adopted, the current Annex I (incl. leather) remains the law.** ## 9. Geolocation requirement (Art. 2(28)) - Latitude/longitude in **WGS84**, to **at least 6 decimal places**. - A **polygon** is required for any **plot larger than 4 hectares**; a single point is allowed for plots ≤ 4 ha. - "Plot of land" (Art. 2(27)): land within a single property with sufficiently homogeneous conditions to allow aggregate risk evaluation. - Accepted formats in practice include GeoJSON, WKT and coordinate lists; check the current TRACES upload spec. - Simplified relief: micro/small **primary** operators (natural persons / micro/small undertakings established in a **low-risk** country who place/export goods they themselves grew/harvested/raised) may use a one-off **simplified declaration**, and a **postal address** may be accepted in lieu of coordinates in some cases. ## 10. Enforcement & penalties **Mandatory annual checks by competent authorities (Art. 16):** - High-risk: at least **9%** of operators/traders **and** 9% of the quantity. - Standard-risk: at least **3%** of operators/traders. - Low-risk: at least **1%** of operators/traders. **Penalties (Art. 25)**: effective, proportionate, dissuasive: - Fines proportionate to environmental damage and product value; for a legal person the **maximum must be at least 4% of total annual EU-wide turnover** (increasable for repeats). - Confiscation of products and/or revenues. - Exclusion from public procurement and public funding for up to 12 months. - Temporary ban from placing/making available/exporting, for serious or repeated breaches. - Prohibition from using simplified due diligence. ## 11. Supplier data request: copy-paste template > **Subject: EUDR data request, geolocation and legality evidence for [product]** > > We are preparing for the EU Deforestation Regulation (EU 2023/1115), which applies to our > [product] from [30 December 2026 / 30 June 2027]. To place these goods on the EU market we > must collect and verify the following for every shipment you supply. Please return this for > each lot: > > 1. **Product** name, **CN/HS customs code**, and **quantity** per shipment. > 2. **Country and region of production.** > 3. **Plot geolocation:** latitude and longitude (WGS84, at least 6 decimal places) for each > plot of land where the commodity was produced. For any plot **larger than 4 hectares**, > a **polygon** (GeoJSON or an ordered coordinate list). > 4. **Production / harvest date** or date range. > 5. **Legality evidence:** land-use rights / title, harvest or production permits, and any > relevant certificates, showing production was legal in the country of origin. > 6. **Deforestation-free confirmation:** written confirmation that no plot was deforested > after **31 December 2020** (and, for wood, no forest degradation after that date). > 7. If you are yourself covered by the EUDR for these goods, the **DDS reference number and > verification number** so we can quote it. > > Please flag any plot you cannot geolocate, and any sub-supplier or co-operative we should > contact directly. We keep this data for 5 years for compliance and audit. Deadline for your > reply: [date]. ## 12. Glossary - **Operator / Trader / Downstream operator**: see §4. - **Relevant products** (Art. 2(2) + Annex I), products that contain, were fed with, or were made using the seven commodities. - **Deforestation-free** (Art. 2(13)), produced on land not deforested after 31 Dec 2020; for wood, no forest degradation after that date. - **Plot of land** (Art. 2(27)) / **Geolocation** (Art. 2(28)), see §9. - **DDS**: Due Diligence Statement, the Annex II electronic declaration filed in the EU Information System. - **Reference number**: unique ID issued on DDS submission; passed down the chain. - **Verification number**: companion ID used with the reference number to look up a DDS. - **Competent authority**: member-state authority that enforces the EUDR. - **Simplified due diligence** (Art. 13), reduced obligations for low-risk-country origins. ## 13. Sources **Primary / EUR-Lex** - Consolidated EUDR (applicable from 26 Dec 2025): https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02023R1115-20251226 - Legissum summary: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=LEGISSUM%3A4680738 - Country benchmarking, Implementing Reg (EU) 2025/1093, search EUR-Lex CELEX 32025R1093. **European Commission** - DG ENV EUDR homepage: https://environment.ec.europa.eu/topics/forests/deforestation/regulation-deforestation-free-products_en - Implementation hub (Green Forum): https://green-forum.ec.europa.eu/deforestation-regulation-implementation_en - Information System / TRACES: https://green-forum.ec.europa.eu/nature-and-biodiversity/deforestation-regulation-implementation/information-system-deforestation-regulation_en - Guidance document: https://green-forum.ec.europa.eu/publications/guidance-document-regulation-eu-20231115-deforestation-free-products_en - FAQ: https://environment.ec.europa.eu/publications/faq-eudr-implementation_en - SME factsheet: https://green-forum.ec.europa.eu/deforestation-regulation-implementation/factsheet-smes_en - TRACES live server: https://eudr.webcloud.ec.europa.eu/tracesnt/ **Amendments / delay & simplification** - Council press release, second delay & simplification (18 Dec 2025): https://www.consilium.europa.eu/en/press/press-releases/2025/12/18/deforestation-council-signs-off-targeted-revision-to-simplify-and-postpone-the-regulation/ - Parliament adopts postpone & simplify (11 Dec 2025): https://www.europarl.europa.eu/news/en/press-room/20251211IPR32168/deforestation-law-parliament-adopts-changes-to-postpone-and-simplify-measures - EY, application postponed to 30 Dec 2026: https://taxnews.ey.com/news/2026-0237-eu-deforestation-regulation-application-postponed-to-30-december-2026 **Simplification review / Annex I (4 May 2026)** - Baker McKenzie: https://www.bakermckenzie.com/en/insight/publications/2026/05/eu-commission-publishes-simplification-review-of-eudr - Mongabay (leather removal): https://news.mongabay.com/2026/05/eu-moves-to-drop-leather-from-deforestation-law-after-industry-lobbying/ - edie (leather removal): https://www.edie.net/eu-to-remove-leather-from-flagship-anti-deforestation-law/ This is guidance, not legal advice. Confirm against the official EUR-Lex, European Commission and TRACES sources before relying on any point, especially items marked `// VERIFY`.