The EU Deforestation Regulation (EUDR) is bringing new sourcing and due diligence requirements to businesses that sell certain products in the EU.
To help you make sense of these new requirements, we’ve put together this guide explaining how EUDR applies to consumer brands, which products are covered and what you should do to comply.
EUDR: a 30-second overview
The EU Deforestation Regulation covers specified products associated with cattle, cocoa, coffee, oil palm, rubber, soya and wood. Businesses placing relevant products on the EU market or exporting them may need to meet due diligence, traceability and record-keeping requirements.
Large and medium operators must comply from 30th December 2026. Most micro and small primary operators have until 30th June 2027, while products newly added to EUDR in 2026 become subject to the Regulation from 30th December 2027.
What is EUDR?
EUDR is the EU Deforestation Regulation (EU) 2023/1115. It is designed to prevent specified products linked to deforestation and forest degradation from being placed on the EU market or exported from it.
It covers products associated with seven commodities:
- Cattle
- Cocoa
- Coffee
- Oil palm
- Rubber
- Soya
- Wood
For a product to comply with EUDR, it must be deforestation-free and produced in accordance with the relevant legislation of its country of production. It must also be covered by a due diligence statement (DDS) or, where the conditions are met, a simplified declaration submitted by a micro or small primary operator.
These commodities must not have been produced on areas that were deforested after 31st December 2020. Wood is also subject to requirements relating to forest degradation after that date.
How do you know if a product is in scope of EUDR?
Products aren't automatically in scope just because they contain cocoa, palm oil, rubber or another EUDR commodity. EUDR applies to the products listed in Annex I of the Regulation, which are identified using customs codes.
Start by checking the CN code for your product against Annex I. It’s the classification of the finished product that determines whether it is in scope. Certain chocolate products, for example, are listed in Annex I, while other foods containing cocoa fall under a classification that isn't included. The same applies to products containing palm-derived ingredients, rubber, wood and other EUDR commodities.
Annex I has changed since EUDR was adopted, so make sure you're working from the current version. Products added in 2026 become subject to EUDR from 30th December 2027. If you carried out your EUDR scope review before these changes, it's worth reviewing your product list again.
EUDR product scope changes in 2025 and 2026
This table summarises the main product-scope changes rather than reproducing the full Annex I. Check the current Annex and applicable CN code when assessing an individual product.
Who is responsible for EUDR due diligence?
Your EUDR responsibilities depend on your role in the supply chain.
The upstream operator first placing a relevant product on the EU market or exporting it is generally responsible for carrying out due diligence and submitting the DDS, unless the simplified declaration provisions for micro or small primary operators apply.
Amendments made in December 2025 reduced duplicated due diligence further down the supply chain and introduced the term “downstream operator” for businesses using products that have already been through the EUDR due diligence process.
Downstream operators and traders must keep specified information about the businesses that supply them and those they supply. The first downstream operator or trader must also collect and keep the relevant DDS reference number or simplified declaration identifier where its supplier is an operator.
Non-SME downstream operators and traders must also register in the EUDR Information System. Records required under these rules must be kept for at least five years.
EUDR non-compliance
If a downstream operator or trader becomes aware of information suggesting that a product it has supplied may not comply with EUDR, you must notify the relevant competent authorities and businesses further down the supply chain.
Where a non-SME downstream operator or trader receives a substantiated concern, you must verify that due diligence was exercised and that no or only negligible risk was found. You must not place or make the relevant product available on the market, or export it, unless that verification demonstrates no or only negligible risk of non-compliance.
What does EUDR due diligence involve?
For operators, due diligence starts with gathering information about the product and where the commodity came from.
Depending on the product and supply chain, this can include:
- A description and quantity of the product
- The commodity it contains or was made from
- Country of production
- Supplier and customer details
- Date or time range of production
- Geolocation of the plots or production areas
- Evidence that the commodity meets the deforestation requirements
- Evidence that it was produced in accordance with the relevant legislation of the country of production
The operator then assesses the risk that the product does not comply with EUDR. If the risk is more than negligible, measures must be taken to reduce it before the product can be placed on the EU market or exported.
For many consumer brands, information needed for due diligence will be held by suppliers, particularly production and geolocation data. You may therefore need to review what information your suppliers can provide and how you will obtain it.
Can certification help with EUDR?
Certification schemes such as Rainforest Alliance can provide information that supports EUDR due diligence, but certification alone isn't enough to demonstrate compliance.
Operators still need to carry out the due diligence required under EUDR and make sure they have the necessary information and evidence.
There is no official “EUDR certified” status. If a supplier describes a product or material as EUDR certified or EUDR compliant, check what evidence they can provide and whether it gives you the information you need for your own EUDR obligations.
Does country risk affect EUDR due diligence?
EUDR classifies countries as low, standard or high risk through its benchmarking system.
Where the relevant commodities were produced in a country, or parts thereof, classified as low risk, you may be able to use simplified due diligence, provided the conditions in the Regulation are met.
You still need to collect the information required under EUDR and consider whether commodities from other countries could have entered the supply chain, or whether there is a risk that the rules are being circumvented. If the conditions for simplified due diligence are met, you do not normally need to carry out the full risk assessment and risk mitigation process.
If information emerges suggesting that a product may not comply with EUDR, the full risk assessment and mitigation requirements apply.
Country classifications also affect enforcement, with competent authorities required to carry out more checks on operators and products associated with high-risk countries.
Does EUDR apply to UK businesses?
UK businesses selling products into the EU can be affected by EUDR. Where a business is established outside the EU, the way the goods are placed on the EU market will determine where the operator responsibilities fall.
The position within the UK also differs between Northern Ireland and Great Britain.
Does EUDR apply in Northern Ireland?
EUDR applies in Northern Ireland under the arrangements that maintain its access to the EU single market.
Large and medium operators must comply from 30th December 2026. The same date applies to micro and small primary operators dealing with wood products already covered by the EU Timber Regulation.
For most other micro and small primary operators, the rules apply from 30th June 2027. Products newly added in 2026 have a later application date of 30th December 2027.
Businesses moving products from Great Britain to Northern Ireland may have EUDR obligations even though the Regulation does not apply directly in Great Britain.
Does EUDR apply in Great Britain?
EUDR does not apply directly in England, Scotland or Wales.
The UK Government is developing a separate deforestation regime for Great Britain, including regulations under the Environment Act 2021 and strengthened UK Timber Regulation legislation.
The Government intends the GB regime to use broadly similar information requirements to EUDR, with legislation currently expected in 2027.
If your business sells across Great Britain, Northern Ireland and the EU, you may therefore be working with different regulatory requirements depending on where a product is being sold or moved.
How does EUDR affect food and drink brands?
Several EUDR commodities are widely used in food and drink, including cocoa, coffee, cattle, soya and oil palm.
Some finished food products are also listed in Annex I. These include specified chocolate and cocoa products, coffee products and preparations containing coffee, along with certain products derived from cattle, soya and oil palm.
If you sell products that fall within Annex I, your responsibilities will depend on your role in the supply chain. You may also need information from suppliers about where the commodity was produced and evidence to support your EUDR due diligence.
How does EUDR affect beauty and personal care brands?
Oil palm is likely to be one of the main commodities beauty and personal care brands encounter under EUDR, particularly where palm-derived materials are used in the supply chain.
The 2026 amendment to Annex I added further palm-oil-derived products, including specified soap products. These additions become subject to EUDR from 30th December 2027.
Beauty businesses may also be affected if you buy or sell other products listed in Annex I, including certain rubber or wood products.
How does EUDR affect furniture, fashion and other consumer goods?
EUDR covers a range of wood products, including specified furniture, so businesses in this sector may need to trace the wood used back through the supply chain.
Fashion and accessories businesses may still encounter EUDR through relevant products made from commodities such as natural rubber or wood. Cattle hides, skins and leather were removed from Annex I in 2026, so businesses should check the current Annex and CN classification of individual products.
Packaging needs to be considered separately. Whether packaging falls within EUDR can depend on whether it is sold as a product in its own right or used to support, protect or carry another product.
EUDR compliance deadlines
The EUDR timetable has been postponed twice since the Regulation was adopted, so older guidance and compliance materials may show different dates. The deadlines now in force are:
Once the applicable date has passed, businesses within scope need to meet the due diligence, traceability and record-keeping requirements that apply to them on an ongoing basis.
How do I know if my business is micro or small?
Business size under EUDR isn't based on employee numbers alone. The criteria come from the EU Accounting Directive and take into account annual turnover and balance-sheet total as well as average employee numbers.
Following the latest inflation adjustment, a micro-undertaking generally does not exceed at least two of the following thresholds:
- €450,000 balance-sheet total
- €900,000 net turnover
- An average of 10 employees during the financial year
Under the Accounting Directive, a small undertaking generally does not exceed at least two of the applicable balance-sheet, turnover and employee thresholds. Member States may set higher financial thresholds within the limits permitted by the Directive.
Member States can set higher financial thresholds for small undertakings within the limits allowed by the Accounting Directive.
Your business classification can affect when EUDR starts to apply to you, so it's worth checking all three criteria when working out your compliance deadline.
What are the penalties for EUDR non-compliance?
EU Member States set and enforce their own penalties for breaches of EUDR, within the framework set by the Regulation.
Depending on the infringement, penalties can include fines, confiscation of products or revenue, temporary exclusion from public procurement and temporary restrictions on selling or exporting products covered by EUDR.
For legal persons, the maximum fine available under national rules must be at least 4% of the operator's, downstream operator's or trader's total annual EU-wide turnover in the financial year preceding the fining decision. Higher fines may be imposed where needed to ensure the penalty exceeds any financial benefit gained from the infringement.
What should consumer brands do to prepare for EUDR?
The steps you need to take will depend on the products you sell and your role in the supply chain. As a starting point, consumer brands can:
- Check the CN codes of finished products against the current Annex I.
- Identify your role in the supply chain for each relevant product.
- Confirm which EUDR compliance date applies.
- Map relevant suppliers and countries of production.
- Identify the sourcing, production and geolocation information you may need.
- Review how information and supporting evidence will be collected and retained.
- Put a process in place to review new products, suppliers and sourcing changes.
If you depend on suppliers for information needed to meet your EUDR obligations, consider whether your agreements cover what needs to be provided and when.
You'll also need to decide who is responsible for EUDR internally, where supporting information will be stored and how records will be maintained.
Keeping your EUDR compliance up to date
Product ranges and supply chains evolve, so your EUDR assessments may need to be revisited when you introduce a new product, change supplier or source ingredients and materials from somewhere new.
Keep a record of which products are in scope and the basis for your assessment, along with your role in the supply chain. Where you're responsible for due diligence, you'll also need access to the sourcing, production and geolocation information required for the products you sell.
If you're unsure which products are in scope, what information you need from suppliers or where responsibility sits in your supply chain, Hooley Brown can help.
We can support you in assessing which products fall within EUDR, understanding your responsibilities and identifying the information and processes you'll need to prepare for compliance.
Book an online call with our team to talk through EUDR for your business.
EUDR FAQs
Is every product containing an EUDR commodity covered?
No. EUDR applies to the commodities and products listed in Annex I. A finished product containing cocoa, palm oil, rubber or another EUDR commodity isn’t automatically in scope, so check its customs classification against the current Annex.
What is the EUDR deforestation cut-off date?
The cut-off date is 31st December 2020. Commodities must not come from areas that were deforested after that date, while additional forest degradation requirements apply to wood.
This date is used to determine whether a product meets EUDR's deforestation requirements; it isn't a compliance deadline.
Do small businesses have to comply with EUDR?
Yes, small businesses can have obligations where they fall within the Regulation. The application dates and requirements depend on their role.
Most micro or small primary operators have until 30th June 2027, although the rules apply from 30th December 2026 to micro or small primary operators dealing with products previously covered by the EU Timber Regulation.
Qualifying micro or small primary operators can also use a simplified declaration.
What information should I ask suppliers for under EUDR?
If you're responsible for EUDR due diligence, you may need information from suppliers including the country of production, production dates, geolocation of relevant plots or production areas and evidence that the commodity meets the deforestation and legality requirements.
The exact information you need will depend on the product, commodity, supply chain and your role under EUDR, so it's worth identifying these requirements before approaching suppliers.
Can certification prove EUDR compliance?
No. Certification schemes can provide evidence to support due diligence, but they don't replace the process required under EUDR. There is no official EUDR certification.
Does EUDR apply to UK companies?
UK companies can have EUDR obligations when selling products into the EU, depending on how those products are placed on the market.
EUDR also applies in Northern Ireland. It does not apply directly in Great Britain, where the UK Government is developing a separate deforestation regime.
This article was originally written in April 2024 and updated in September 2026 to reflect updates to EUDR. Regulations and official guidance can change, so check the requirements that apply to your products and circumstances.
