EU Deforestation Regulation
The EU's deforestation-free products regulation requires full supply chain traceability with geolocation data for seven commodities. After a 12-month Omnibus postponement, large operators must comply by 30 December 2026. The cut-off date remains 31 December 2020.
The EU Deforestation Regulation is a European law that says: if you want to sell certain products in Europe, you need to prove they were not grown on land that was recently deforested. "Recently" means after 31 December 2020. It does not matter whether the deforestation was legal in the country where it happened -- what matters is that no forest was cleared to produce the goods.
The regulation targets seven commodities that are major global drivers of deforestation: cattle, cocoa, coffee, oil palm, rubber, soya, and wood. It also covers the many products derived from these commodities -- from chocolate and leather to furniture and tyres. If your product contains, was fed with, or was manufactured using any of these raw materials, it likely falls within scope.
In practical terms, companies must collect geolocation data that traces each commodity back to the specific plot of land where it was produced. They must assess the risk that the land was deforested, and if the risk is anything above negligible, they must either fix the problem or stop selling that product in Europe. A formal due diligence statement must be filed electronically before the goods can enter the EU market.
The original application date was 30 December 2024. A first postponement (Regulation 2024/3234, adopted December 2024) pushed it to 30 December 2025. Then the Omnibus simplification (Regulation 2025/2650, adopted February 2025) added another 12 months. Large and medium companies now have until 30 December 2026. Smaller businesses get an extra six months, until 30 June 2027, and benefit from simplified procedures including the option to use postal addresses instead of precise GPS coordinates when sourcing from low-risk countries.
Switzerland is not an EU member state, but Swiss companies that export to the EU single market are fully subject to the EUDR. Any operator or trader who places regulated products on the EU market -- or exports them from the EU -- must comply, regardless of where the company is headquartered. Switzerland has been classified as a low-risk country in the Commission's benchmarking list, which means Swiss-origin commodities qualify for simplified due diligence. However, Swiss companies sourcing from standard- or high-risk countries must perform the full due diligence process. The Swiss government has not adopted an equivalent domestic regulation, so EUDR compliance is driven entirely by EU market access requirements.
The EU Deforestation Regulation (EUDR), published as Regulation (EU) 2023/1115 and revised by Regulation (EU) 2025/2650 in December 2025, is the EU's most ambitious attempt to break the link between European consumption and global deforestation. It prohibits the placing on or export from the EU market of seven key commodities -- cattle, cocoa, coffee, oil palm, rubber, soya, and wood -- and their derived products unless they are verified as deforestation-free and produced in compliance with local laws. The cut-off date is 31 December 2020: any product linked to land deforested after that date cannot enter the EU market.
The regulation applies to all operators and traders regardless of company size or country of origin. If you place regulated commodities or derived products on the EU market, you must comply. The December 2025 Omnibus revision introduced a new "downstream operator" category for processors further along the supply chain and created simplified obligations for micro and small primary operators sourcing from low-risk countries. Printed products (books, newspapers) were removed from scope entirely.
At the heart of EUDR is an unprecedented geolocation requirement. Operators must collect the precise geographic coordinates of every plot of land where regulated commodities were produced. For plots under 4 hectares, a single point with area size suffices; for larger plots, a full polygon boundary is required. This data must be submitted through the EU Information System alongside a due diligence statement before goods can be placed on the market. There are no exemptions from the geolocation obligation.
The Commission's country benchmarking system classifies producing countries into three risk tiers: low, standard, and high. As of May 2025, 140 countries are classified as low risk (including all EU member states), approximately 50 as standard risk (including Brazil, Indonesia, and Malaysia), and four as high risk (Belarus, Myanmar, North Korea, Russia). The risk tier determines both the depth of due diligence required and the frequency of checks by competent authorities -- 1% for low-risk, 3% for standard, and 9% for high-risk sources.
Following two postponements -- first from December 2024 to December 2025, then to December 2026 under the Omnibus simplification -- large and medium operators must comply by 30 December 2026, with micro and small operators given until 30 June 2027. The Commission was required to deliver a simplification report by 30 April 2026 evaluating administrative burden, particularly on SMEs. Despite the delays, the underlying obligations remain substantively unchanged, and companies are strongly advised to use the remaining time to build traceability systems rather than postpone preparation.
EUDR does not operate in isolation. It replaces the EU Timber Regulation, aligns with the Corporate Sustainability Due Diligence Directive (CSDDD) and CSRD, and complements the EU's broader Green Deal ambitions. A 2028 review may extend its scope to other ecosystems such as wetlands and savannas, and potentially bring financial institutions within its reach.
The EUDR covers seven commodity groups and all products derived from them. If your product contains, was fed with, or was made using any of these commodities, it falls under EUDR scope.
The 2025 Omnibus revision removed printed products (books, newspapers, printed pictures) from the EUDR scope. A 2028 review may extend the regulation to cover other ecosystems (wetlands, peatlands, savannas) and potentially bring financial institutions into scope.
The five-step process every operator must follow before placing regulated products on the EU market.
Products may only be placed on the EU market if, after completing due diligence, the risk of deforestation linkage is assessed as "negligible." If the risk is anything above negligible, the operator must either mitigate it to negligible or refrain from placing the product on the market.
Regulation (EU) 2025/2650 introduced targeted changes to ease implementation while preserving core obligations.
Select your company type for tailored compliance guidance.