What Is the EUDR? A Complete Overview of the EU Deforestation Regulation

What Is the EU Deforestation Regulation?

The EU Deforestation Regulation (EUDR), formally known as Regulation (EU) 2023/1115, is a landmark piece of EU legislation that aims to minimize the European Union's contribution to global deforestation and forest degradation. It replaces the older EU Timber Regulation (EUTR) and significantly expands its scope to cover seven key commodities.

The regulation entered into force on 29 June 2023 and establishes mandatory due diligence requirements for companies placing certain commodities on the EU market or exporting them from the EU. Unlike its predecessor, the EUDR requires operators to collect and verify geolocation data for every production plot. This is a fundamental shift toward plot-level traceability.

For EU coffee importers preparing for compliance, the shift from document-based due diligence under the EUTR to plot-level geolocation requirements is a major operational change. Understanding the full scope of the regulation is the first step toward building a compliance strategy that works.

Why Was the EUDR Introduced?

The EU is one of the world's largest consumers of commodities linked to deforestation, including coffee, cocoa, soy, palm oil, cattle, rubber, and wood. According to the European Commission's 2019 Communication on Stepping up EU Action to Protect and Restore the World's Forests, EU consumption accounts for approximately 10% of global deforestation.

The EUDR was introduced to:

• Reduce the EU's deforestation footprint by ensuring that products consumed in the EU are "deforestation-free"
• Protect biodiversity and the rights of indigenous peoples in producer countries
• Combat climate change, since deforestation is a major source of global greenhouse gas emissions
• Create a level playing field for businesses that already source responsibly, removing the competitive disadvantage of sustainable practices
• Close the gaps in the EUTR, which only covered timber and had limited enforcement mechanisms

The political momentum behind the EUDR built over several years, reflecting broad consensus that voluntary approaches to deforestation were insufficient.

How the EUDR Differs From the EU Timber Regulation (EUTR)

The EUDR is not simply an update to the EUTR. It is a fundamentally different regulatory approach:

For operators who were compliant under the EUTR, the EUDR requires significant new capabilities, particularly around geolocation data collection and validation and the new DDS submission process.

What Products Are Covered?

The regulation covers seven key commodities and their derived products:

1. Coffee: coffee products listed under Annex I, currently centred on HS 0901. For coffee importers, every covered bag of green or roasted coffee entering the EU must be traceable to the production plot.
2. Cocoa: cocoa beans, paste, butter, powder, chocolate, and other listed cocoa preparations
3. Soy: soybeans, soy flour or meal, soybean oil, and oilcake or solid residues used in feed
4. Palm oil: listed oil palm products, including palm oil, palm kernel oil, palm nuts and kernels, and oilcake or residues
5. Cattle: live bovine animals, beef and veal, selected offal and preparations, raw hides and skins, and specified leather headings
6. Rubber: natural rubber, latex, tires, and other listed rubber products
7. Wood: timber, sawn wood, charcoal, wood-based panels, pulp, paper, and selected furniture or prefabricated wood products

Relevant products are identified using Harmonized System (HS) codes as listed in Annex I of the regulation. It is important to verify your specific product's HS code against Annex I, as not all products within a commodity chapter are necessarily covered. For a detailed breakdown of HS codes and how to check your products, see our guide on who needs to comply with the EUDR.

Who Needs to Comply?

The amended EUDR distinguishes between upstream operators, downstream operators, and traders. A special simplified regime applies to qualifying micro or small primary operators.

Operators

Companies that first place relevant products on the EU market or export them. For importers, this often means the company identified by the EORI number used in the customs declaration. Operators generally carry out due diligence and submit a DDS. Qualifying micro or small primary operators instead submit a one-time simplified declaration and may, under the conditions in Article 4a, provide a postal address instead of plot geolocation.

Downstream Operators and Traders

Downstream operators place or export relevant products made entirely from products already covered by upstream due diligence. Traders make relevant products available on the market without being an operator or downstream operator. These downstream actors do not carry out a second full due diligence process or submit another DDS. All must keep specified supplier and buyer information for five years. Non-SME downstream actors must also register in the Information System, and verification of upstream due diligence is required when a substantiated concern arises. Only the first downstream buyer from an upstream operator or micro or small primary operator must collect the relevant DDS reference number or simplified-declaration identifier.

For a detailed breakdown of operator vs. trader obligations, HS codes, EORI requirements, and exemptions, see our dedicated article: Who Needs to Comply With the EUDR?

The Core Requirement: Deforestation-Free

For products to be placed on the EU market, operators must demonstrate that they are:

1. Deforestation-free: the commodities were not produced on land that was deforested after 31 December 2020. This is the fixed cutoff date set by the regulation.
2. Legally produced: produced in accordance with the relevant legislation of the country of production, including land use rights, environmental protections, labour laws, and tax obligations
3. Covered by the required declaration: an upstream operator generally submits a Due Diligence Statement (DDS) before placing or exporting the products. A qualifying micro or small primary operator uses a one-time simplified declaration instead. Products handled further downstream must already be covered by one of these declarations.

The term "deforestation" in the regulation means the conversion of forest to agricultural use. "Forest degradation" is also addressed for wood products, where the regulation looks at specific structural changes in forest cover after the 2020 cutoff.

The Three-Step Due Diligence Process

Operators must implement a due diligence system consisting of three mandatory steps:

Step 1: Information Collection

Gather comprehensive data about your supply chain, including:

• Geolocation coordinates of all production plots. GeoJSON is the Information System's bulk-upload format, but the law does not require GeoJSON when coordinates are entered through another accepted system method.
• Supplier names, addresses, and contact details
• Product descriptions, HS codes, and quantities
• Country of production and harvesting dates
• Evidence of legal compliance in the country of production

Step 2: Risk Assessment

Evaluate whether the products present no or only a negligible risk of being linked to deforestation or illegal production. Relevant inputs can include country risk benchmarks, remote-sensing evidence, and supply chain complexity. Where the assessment does not establish no or negligible risk, mitigation measures are required before the products may be placed on the market or exported.

Step 3: Risk Mitigation

If risk is identified as non-negligible, take adequate steps to reduce it before placing products on the market. This may include requesting additional documentation, switching suppliers, or conducting on-the-ground verification.

Bosqio treats these steps as one evidence record: plot capture, producer submissions, legality documents, remote-sensing checks, risk decisions, and the DDS evidence package stay linked.

What Competent Authorities Do

Each EU member state designates one or more competent authorities responsible for enforcing the EUDR. Their powers include:

• Inspecting operators and traders: checking DDS submissions, supply chain records, and geolocation data
• Requesting additional information: operators must respond to information requests within a reasonable timeframe
• Ordering product withdrawals: if products are found to be non-compliant, they can be removed from the market
• Imposing penalties: fines with a maximum level of at least 4% of annual EU-wide turnover, product confiscation, temporary exclusion from public procurement, and prohibition from placing products on the market

The minimum check rates are tied to the country benchmarking system: Member State competent authorities check at least 1% of relevant actors for low-risk origins, 3% for standard-risk origins, and 9% for high-risk origins. For high-risk origins, they must also check at least 9% of the relevant product quantity.

Practical Implications for Coffee Importers

Coffee is one of the commodities most directly affected by the EUDR, particularly because of the complexity of coffee supply chains. A typical coffee importer may source from hundreds of smallholder farmers through cooperatives and exporters across multiple countries.

Key practical challenges for coffee importers include:

• Geolocation data from smallholders: many smallholder farmers have never had their plots mapped with GPS. The 4-hectare rule helps by allowing point coordinates for small plots, but data collection at scale remains a significant undertaking.
• Blending and co-mingling: coffee is often blended from multiple origins at export. Each origin must be traced back to compliant plots, which requires robust segregation or detailed tracking through the supply chain.
• Supplier readiness: exporters and cooperatives in producing countries need systems to collect, validate, and transmit geolocation data. Many are still building these capabilities.
• Timeline pressure: with the main application date approaching on 30 December 2026, the window for preparation is narrowing. Operators who have not yet established their due diligence systems are already at risk.

Frequently Asked Questions

Does the EUDR apply to products already in the EU?

Products placed on the EU market before the applicable date are generally outside the new obligations if the date of placement can be demonstrated. Production date also matters: except for the special timber transition in Article 37, the EUDR does not apply to relevant products produced before 29 June 2023. Timber and timber products covered by the former EUTR follow specific transitional rules through 31 December 2029.

What is the difference between "deforestation" and "forest degradation"?

Deforestation means the conversion of forest to agricultural use. Forest degradation is a separate concept mainly relevant to wood products and refers to specific structural changes, such as conversion of primary or naturally regenerating forest into plantation forest or other wooded land.

Can I rely on third-party certifications (like Rainforest Alliance) instead of conducting my own due diligence?

No. Certifications and third-party verification schemes can be used as supporting evidence, but they do not replace the operator's own due diligence obligations. An upstream operator must still collect the required information, assess risk where applicable, and submit the required DDS. The simplified regime for qualifying micro or small primary operators and the separate obligations of downstream actors remain unaffected.

What happens if my supplier cannot provide geolocation data?

An upstream operator that cannot obtain the geolocation information required by Article 9 cannot complete compliant due diligence or place the affected products on the market. The limited exception is the Article 4a regime for qualifying micro or small primary operators, who may provide a postal address that clearly identifies the relevant plots or cattle establishment. Downstream operators and traders do not collect plot data as part of a new due diligence process, but they must meet their own traceability obligations.

Is the EUDR the same across all EU member states?

The regulation itself is directly applicable across all 27 EU member states. It does not need to be transposed into national law. However, enforcement is handled by national competent authorities, and the level of enforcement activity and penalty severity may vary between member states.

Sources

• Consolidated Regulation (EU) 2023/1115: Current consolidated text of the EU Deforestation Regulation
• Regulation (EU) 2025/2650: Amendments to timeline, roles, and product scope
• Commission Implementing Regulation (EU) 2025/1093: Country benchmarking classification
• European Commission: Deforestation: Official information page
• European Commission: EUDR Information System: Platform for DDS submission
• European Commission (2019): Stepping up EU Action to Protect and Restore the World's Forests: Communication on EU deforestation footprint