Last updated: 3rd September 2026
The EU is implementing the EUDR to minimise products circulating on the market that have contributed to global deforestation.
Following two extensions and various simplification measures, the EU has confirmed that the EUDR will not be re-opened and there will be no further deadline extensions.
Large and medium sized organisations must comply by 30th December 2026, and micro and small enterprises that are not subject to EUTR will have an extended period until 30th June 2027.
Product Scope
Businesses placing products within the categories listed below onto the EU market may have obligations under EUDR. There are no minimum thresholds on product volume, value or company size.
- Coffee
- Rubber
- Cocoa
- Cattle
- Wood*
- Palm oil
- Soy
Please see ANNEX I for a complete list of CN codes in scope.
*Empty packaging made from wood/wood fibers being sold onto the EU market is in scope of EUDR (e.g. flat-packed cardboard boxes), however, filled packaging being used to transport and protect a product is not in scope.
2026 Amendments
An addendum to ANNEX I has recently been published with additions and exclusions to the products in scope:
- Additions: soluble coffee, various palm oil derivatives including soap and cosmetics (apply from 30th December 2027)
- Exclusions: cattle leather, bamboo and rattan, printed products under CN 49, samples and second-hand products.
Roles
| EU Operator | The legal compliance burden of EUDR sits with the company first placing an in scope product onto the EU market – the ‘operator’. When the product does not originate from the EU, this is the company that acts as the EU importer of record, generally in B2B transactions this is the EU based client. |
| Non-EU Upstream Supplier | Scenario 1: it is possible for legal (operator) obligations to fall onto UK/non-EU businesses, where they have used their own EU EORI to act as the EU importer. Under EUDR, there must always be an EU business who is legally responsible, meaning that in this scenario, both the non-EU operator and the first EU business responsible for the product (the EU operator) take legal responsibility, and must carry out due diligence.
Scenario 2: Where the non-EU entity does not act as the EU importer of record, they have no legal EUDR obligations. However, their EU based clients cannot place non-compliant products onto the EU market, meaning they still have a commercial obligation to provide compliant products and pass on the required documentation. |
| Downstream EU Customers | Downstream operators do not need to repeat due diligence where this has already been performed upstream. However, they must collect, record and pass on all DDS references and verify that due diligence has been performed adequately. |
| Online Marketplaces | Online marketplaces that only facilitate online sales between two third parties and have no role in supply of the product to the client are considered a service provider with no legal obligations under EUDR. |
Operator Obligations
- Due diligence must be performed before placing a product on the market:
1. Data collection: product description, quantity, country of production, geolocations, evidence of compliance
2. Risk Assessment: to evaluate the risk of deforestation or legal non-compliance
3. Risk mitigation: where risk is high, actions must be taken to achieve negligible risk, and where this is not possible, products cannot be placed on the market - Due diligence statements (DDS) must be submitted to the EU IT system (Traces) – see ANNEX II for DDS template
- All documentation must be retained for at least 5 years
- All documentation must be provided to EU authorities upon request, as well as all downstream stakeholders
Please see Article 4 for full legal obligations.
UK Deforestation Regulation
The UK government has confirmed that they intend to strengthen the existing UK Timber Regulation (UKTR) with a new deforestation policy. Publication is currently expected in 2027, which is typically followed by an 18-month grace period before the mandatory compliance deadline, allowing businesses time to comply.
The UK government aims to develop this policy to be consistent with the EU Deforestation Regulation (EUDR).
BPMA News: UK Government Announces Intentions to Introduce a Deforestation Regulation
EUDR Case Study Webinar, 29th September 2026
This session explores a range of supply chain scenarios and case studies that may impact UK businesses, including their roles and obligations.
Further Guidance
UK Export Support: Ask the export support team a question
This information is provided as general guidance only. Organisations should refer to the relevant legislative text to determine their full legal obligations.