The EU Deforestation Regulation (EUDR), Regulation (EU) 2023/1115, requires that cattle, cocoa, coffee, oil palm, rubber, soya and wood products are deforestation-free, legal and covered by a due diligence statement. After amendments in 2024 and 2025 it applies from 30 December 2026 for large and medium operators and from 30 June 2027 for micro and small operators. Product data teams need commodity codes, geolocation and statement references linked to items and batches.
The EU Deforestation Regulation (EUDR), Regulation (EU) 2023/1115, is the EU law that allows cattle, cocoa, coffee, oil palm, rubber, soya and wood, and listed products made from them, on the EU market only if they are deforestation-free, legally produced and covered by a due diligence statement. After two postponements it applies from 30 December 2026 for large and medium-sized operators and from 30 June 2027 for micro and small operators.
What does the EUDR require?
The EUDR requires three conditions for every relevant product:
- Deforestation-free: produced on land not subject to deforestation (or, for wood, forest degradation) after the cut-off date of 31 December 2020.
- Legal: produced in line with the relevant laws of the country of production.
- Covered by a due diligence statement: submitted to the EU information system before placing on the market or export.
Relevant products are defined by customs codes in Annex I, which makes the customs code (CN or HS) the main scoping attribute in product data.
What changed in 2024, 2025 and 2026?
The EUDR has been amended several times since it entered into force on 29 June 2023. The table shows the key steps as of 17 October 2026.
| Date | Change | Effect |
|---|---|---|
| 29 June 2023 | Regulation (EU) 2023/1115 enters into force | Original application 30 December 2024 |
| December 2024 | Regulation (EU) 2024/3234 | Application moved to 30 December 2025 (30 June 2026 for micro and small) |
| May 2025 | Country benchmarking implementing act | Countries classed as low, standard or high risk |
| 26 December 2025 | Regulation (EU) 2025/2650 in force | Application moved to 30 December 2026 (30 June 2027 for micro and small); downstream simplification; printed products removed |
| Early May 2026 | Commission simplification review and draft scope delegated act | Report, updated guidance and FAQs |
| 18 September 2026 | Delegated Regulation (EU) 2026/2102 in force | Leather, several rubber articles, soybeans for sowing and second-hand products removed; new products added |
| 30 December 2027 | Newly added products covered | Soluble coffee, palm oil derivatives, frozen bovine tongues |
No further postponement of the 30 December 2026 date had been adopted as of 17 October 2026.
Who must do what after the 2025 amendment?
Regulation (EU) 2025/2650 concentrated the main obligations on the first operator in the chain:
- Operators placing products on the EU market for the first time, or exporting them, carry out due diligence (information collection, risk assessment, risk mitigation) and submit the statement.
- Micro and small primary operators, particularly in low-risk countries, can use a simplified declaration.
- Downstream operators and traders no longer submit their own statements; they keep supplier and customer records for five years and pass on reference numbers, with additional checks where there is concrete evidence of non-compliance.
Which product data does the EUDR require?
EUDR compliance depends on data that sits partly in PIM and partly in sourcing and ERP systems. The table shows a typical split.
| Data point | Level | Typical master |
|---|---|---|
| CN or HS code and EUDR relevance flag | Item | PIM or ERP |
| Commodity and share of relevant material | Item or BOM | PLM or PIM |
| Country of production | Batch or lot | Sourcing or ERP |
| Geolocation of plots (points, or polygons for plots above 4 hectares) | Lot | Supplier portal or traceability tool |
| Due diligence statement reference and verification numbers | Shipment or batch | ERP or compliance tool |
| Supplier and customer identification | Transaction | ERP |
PIM is rarely the right home for geolocation or shipment-level references, but it should hold the scoping attributes and link items to the compliance records. The modelling approach is covered in PIM data model design.
How should product data teams prepare?
Preparation centres on scoping accuracy and supplier data. Customs codes must be correct and current, because Delegated Regulation (EU) 2026/2102 changed Annex I and adds products from 30 December 2027. Supplier questionnaires and certificates should be collected through structured processes described in supplier data onboarding. EUDR data also overlaps with sustainability reporting, covered in CSRD and product data.
Practical next steps
- Re-check customs codes for the full catalogue against the amended Annex I and set an EUDR relevance flag.
- Confirm the organisation's role (first placer, downstream operator or trader) and size category.
- Agree where geolocation and statement references are held and how items link to them.
- Plan for products added from 30 December 2027 and monitor Commission guidance.
Platforms with compliance attribute support are listed in the vendor directory.
Frequently asked questions
When does the EUDR apply?
After Regulation (EU) 2025/2650, the EUDR applies from 30 December 2026 for large and medium-sized operators and traders, and from 30 June 2027 for micro and small operators. Products newly added by Delegated Regulation (EU) 2026/2102 are covered from 30 December 2027.
Is leather still covered by the EUDR?
No. Delegated Regulation (EU) 2026/2102, in force since 18 September 2026, removed raw, tanned and finished bovine hides and leather from Annex I.
Do retailers need to submit due diligence statements?
Following the 2025 amendment, the due diligence statement is submitted by the operator that first places the product on the EU market or exports it. Downstream operators and traders mainly keep records and pass on reference numbers, with extra checks where concrete evidence of non-compliance exists.