As of August 24, 2026 : Many companies are now familiar with the basic requirements of the EU Deforestation Regulation (EUDR): verifying geodata, collecting proof of legality, and submitting a Due Diligence Statement, but preparing for concrete operational implementation within the company often remains a real challenge. Here, you can learn more about the EUDR, take the free Pohlmann & Company self-check, and download our detailed white paper on the topic.
What is the EUDR?
The EU Deforestation Regulation (EU) 2023/1115 (EUDR) allows relevant commodities and products to be placed on the EU market, made available on the market, or exported from the EU only if they are deforestation-free, produced in accordance with the relevant laws of the country of production, and covered by a due diligence statement (DDS) (Article 3 EUDR).
Seven relevant raw materials are covered: cattle, cocoa, coffee, oil palm, rubber, soy, and timber. In addition, there is a comprehensive list of relevant products in Annex I of the EUDR, which is defined by HS codes and covers processed products such as chocolate, furniture, tires, and paper.
What are the deadlines for the EUDR?
The main EUDR obligations will apply from December 30, 2026. For natural persons, micro-enterprises, and small enterprises that already existed as such on December 31, 2024, the deadline is extended until June 30, 2027 – but only if they act as operators, meaning that they place relevant products on the EU market for the first time or export them from the EU. The extension does not apply to products that were already covered by the previous EU Timber Regulation (EUTR).
What roles does the EUDR distinguish?
| Companies | Examples and Explanations |
| Operator | An operator places relevant products on the EU market for the first time or exports them from the EU. This includes, in particular, importers, producers based in the EU, and exporters. |
| Micro or small primary operator | A natural person or a micro or small enterprise based in a low-risk country within the EU that produces relevant products itself and places them on the market for the first time or exports them from the EU. |
| Downstream operator | A downstream operator processes relevant products into other products – such as wood into furniture (the HS code classification is decisive) – or exports relevant products for which a due diligence statement is already available. |
| Trader | A trader is typically a reseller of relevant products without altering them as defined by the customs tariff classification (HS codes). |
Which products are covered by the EUDR?
In July 2026, the European Commission adopted a delegated act amending Annex I of the EUDR. Among other changes, the act removes bovine hides and leather as well as retreaded tires from the product scope and adds products such as instant coffee, frozen beef tongues, and certain palm oil derivatives. For the newly added products, a later application date of December 30, 2027, is envisaged. However, the delegated act is still subject to the objection procedure by the European Parliament and the Council and will become legally binding only once it has been published in the Official Journal.
EUDR Self-Check: Is Your Company Prepared?
The self-assessment within the Self-Check focuses on the requirement for full due diligence.
For more detailed insights of these and other assessment questions, see our white paper “EUDR in Practice: Roles, Legality Assessment, and Implementation Risks.” There, we provide an in-depth explanation of the individual topics and offer supplementary self-assessment questions as well as practical recommendations for implementation.
➡️Read the white paper here (available in english and german)
How Pohlmann & Company Supports You with the EUDR
Pohlmann & Company supports companies at the intersection of law, compliance, governance, and operational processes – not just on an ad hoc basis during implementation, but as a long-term EUDR partner.
- Product Check: Verification of whether specific raw materials and products fall within the scope of the EUDR based on Annex I of the EUDR and the CN or HS codes listed therein (international commodity codes used to classify products in customs and foreign trade).
- Role Check: Verifying the role a company plays in a specific business transaction and within the corporate structure, e.g., as an operator, downstream operator, trader, or small or micro primary operator.
- Impact Analysis: A comprehensive entity-level review of relevant products, trade flows, supply chains, and internal processes to determine which parts of the organization are affected by the EUDR and where action is required.
- Supplier Questionnaires: Structured questionnaires for geolocation data, legality information, traceability data, and other supporting documentation. In this step, we also determine which data, if any, has already been collected through government initiatives.
- Governance workshops: Responsibilities, approvals, and escalation procedures between procurement, compliance, sustainability, customs, IT, and management.
- DDS processes: Operationalization of the preparation, review, approval, submission, and documentation of due diligence statements.
- Legality Review: Technical and legal support in evaluating information and documents based on the relevant legal regulations of the country of origin.
- Risk Assessment and Risk Mitigation: Support with risk assessment pursuant to Article 10 of the EUDR and with risk mitigation measures pursuant to Article 11 of the EUDR.
- Mock Audits: Simulation of a potential regulatory audit, as well as review of internal processes, documentation, and evidence management.
EUDR FAQ 2026: Brief Answers to Frequently Asked Questions
· What does EUDR stand for?
EUDR stands for EU Deforestation Regulation. This refers to Regulation (EU) 2023/1115 on deforestation-free supply chains.
· Where can I find the EUDR text as a PDF?
The official version in all official languages, including PDF, is available via EUR-Lex. For practical purposes, we recommend the consolidated version dated December 26, 2025, which includes the amendments made by Regulation (EU) 2025/2650.
· Has the EUDR been postponed?
Yes. The start date of the EUDR has been postponed several times, most recently by Regulation (EU) 2025/2650. The most important obligations generally apply as of December 30, 2026. For micro and small enterprises already in existence as of December 31, 2024, an extended deadline applies until June 30, 2027. However, this does not automatically apply to every small business, but specifically to businesses acting as operator – that is, businesses that place relevant products on the EU market for the first time or export them from the EU. Furthermore, the extended deadline does not apply to products that were already covered by the previous EU Timber Regulation (EUTR).
· EUDR News 2026: What Has Changed Recently?
In 2026, the Commission published an updated guidance and a new version of the FAQs and further developed the TRACES information system. In addition, a Delegated Act was proposed to amend Annex I of the EUDR and thus the list of covered raw materials and products. For companies, this changes the specific details, not the fundamental obligations
· What is a DDS?
The Due Diligence Statement (DDS) is the declaration submitted via the EU’s TRACES information system, through which a operator confirms that it has fulfilled its due diligence obligations. Relevant products may not be placed on the market or exported without a prior declaration.
· What is the legality verification?
A legality assessment is an evaluation of whether a relevant raw material was produced in accordance with the applicable laws and regulations of the country of origin. It covers, among other things, land-use rights, environmental and forestry laws, third-party rights, labor and human rights, as well as tax, trade, and customs regulations.
· What is simplified due diligence?
For products from low-risk countries, the operator may, pursuant to Article 13 of the EUDR, limit themselves to gathering information if there is no significant risk of circumvention or commingling. Risk assessment and risk mitigation are then not required; however, the information obligations under Article 9 of the EUDR remain in effect.
· Is packaging covered by the EUDR?
According to the Commission’s interpretation, packaging material that serves solely to support, protect, or transport another product is not covered by the EUDR. However, packaging may be covered as a standalone commercial product listed in Annex I. The PPWR sets forth separate requirements for packaging.