What EUDR is
Regulation (EU) 2023/1115 requires that seven commodities and their derived products (chocolate, coffee, palm oil, soy meal, beef, natural rubber, timber, paper and more, listed by customs code in Annex I) come from land that was not deforested after 31 December 2020, and were produced legally. Compliance is proven with a due diligence statement (DDS) filed in the EU Information System, carrying a reference number that follows the goods through the chain.
When it applies
After two postponements, the dates are set: 30 December 2026 for large and medium companies, 30 June 2027 for micro and small enterprises (timber-sector micro and small companies stay on the 2026 date). No further delay is on the table; the Commission has said it will adjust details, not the core text. Penalties reach at least 4 percent of Union-wide turnover.
What role you play decides what you owe
- Operators (importing a commodity, or first placing it on the EU market) carry the full duty: information collection, risk assessment, mitigation, and a DDS with geolocation of every plot of production (a point for plots up to 4 hectares, a polygon above that), kept for five years.
- Downstream operators, which is what most food producers and retailers buying cocoa, coffee, palm or soy ingredients from EU importers are since the December 2025 simplification, do not file a DDS. The first downstream actor collects the DDS reference numbers from suppliers; invoices and standard commercial documents count as evidence.
- Sourcing country matters: the Commission's benchmarking list (May 2025) puts most origins in the low-risk tier, which allows simplified due diligence, but reference numbers and geolocation are still required in every tier.
The data you need per product
- Commodity screening of every bill of materials: which products contain an Annex I commodity, in which ingredient, from which supplier. Coffee extracts and more palm derivatives join the list on 30 December 2027.
- DDS reference and verification numbers per supplied lot, collected from suppliers and kept for five years. One annual DDS can cover shipments for up to a year.
- For direct imports: plot geolocation, production dates, and legality evidence from the producer country.
Proving it deforestation-free lowers the number
This is the part that gets missed, and for anyone reporting at farm level it is often worth more than the compliance itself. A footprint built on averages carries a land-use-change charge that reflects the deforestation risk of the origin, not of your actual supply. Buy a commodity attributed to a high-risk origin and you inherit that charge whether or not a single hectare behind your purchase was ever cleared.
Evidence that your specific plots are clean takes it off. The land-use-change component of the footprint falls, and it falls for every product that contains the ingredient.
From 1 January 2027 the land-sector rules make that trade explicit: a value more specific than the country average may only be used where physical traceability is demonstrated with a chain of custody model. Plot geolocation gathered for EUDR is precisely that evidence. The obligation you are already funding is what unlocks the lower number, so the two programmes should be run as one.
What we cover, and what comes next
The platform carries the downstream duty, which is what most food producers and retailers actually owe. Every bill of materials is screened for Annex I commodities, and DDS reference numbers are collected and held against the product and supplier they belong to, through the same supplier requests that already gather activity data. Your product tree maps each ingredient to its supplier and origin, and land-use change is already a named part of every footprint.
Full operator-side support, meaning plot geolocation, risk assessment and mitigation, and filing the due diligence statement itself, follows as farm-level programmes reach the producers who hold that data. If you are an operator rather than a downstream buyer, say so early and we will fit it to your timeline.
Sources: Regulation (EU) 2023/1115; Regulation (EU) 2025/2650 (dates and simplifications); Implementing Regulation (EU) 2025/1093 (country benchmarking); Commission simplification report COM(2026) 191. This guide is not legal advice.