What changes for exporters under the EUDR on 30 December 2026?
Regulation (EU) 2023/1115 has been in force since 29 June 2023 and now becomes applicable. Its application was postponed twice; Regulation (EU) 2025/2650 of 19 December 2025, published in the Official Journal on 23 December 2025, set the current dates and amended the due diligence obligations. The European Commission states that the regulation repeals the EU Timber Regulation (EUTR).
Point | Until now | From 30 December 2026 |
|---|---|---|
Placing on the EU market or exporting | No deforestation-free proof required (only timber fell under the EUTR) | Prohibited without a due diligence statement filed by the operator |
Proof of origin | Commercial certificates, transport documents | Country of production and geolocation of every plot |
Cut-off date | None | Land not deforested after 31 December 2020 |
Downstream operators and traders | No obligation | Collect and keep information, including the reference numbers of their supplier's statements |
Micro or small primary operators | No obligation | One-time simplified declaration; the plots' postal address can replace geolocation |
Micro and small undertakings apply these rules from 30 June 2027. Products added to the scope by a delegated act come in on 30 December 2027.
Which products and companies are in scope?
Seven commodities are covered: cattle, cocoa, coffee, oil palm, rubber, soy and wood. Annex I extends the scope to many derived products, including:
- chocolate and other food preparations containing cocoa;
- cattle leather further prepared after tanning;
- paper pulp, paper and board falling under chapters 47 and 48 of the Combined Nomenclature, other than bamboo-based and recovered products;
- printed books, newspapers and other products of the printing industry;
- wooden furniture and articles of wood.
The obligation to file falls on the operator that places the product on the EU market or exports it. A supplier based outside the EU generally files nothing, but its customer cannot declare anything without the supplier's data.
In practice, expect each EU buyer to ask, lot by lot, for the product description and its Combined Nomenclature code, the quantity, the country of production, the geolocation of every plot where the commodity was grown, the date or time range of production, and evidence that production complied with the laws of the producing country. Suppliers who can answer from their own traceability system, rather than rebuilding the file for every shipment, will keep their place on approved-supplier lists.
Exporters in Morocco and anglophone Africa
Commission Implementing Regulation (EU) 2025/1093 of 22 May 2025 places every country in one of three risk categories: low, standard or high. Morocco, Ghana and Egypt are classified low risk. For a low-risk origin, the EU operator applies simplified due diligence: it collects the information, geolocation included, without a risk assessment or risk mitigation.
Nigeria and Côte d'Ivoire are classified standard risk. Their cocoa, coffee, rubber and timber exporters will face their buyers' full due diligence: questionnaires, proof of legality, consistency checks on plot data.
For international buyers sourcing from Africa, the key point is that the risk class follows the country where the commodity was grown, not where the product was processed. Chocolate made in Morocco from Ivorian cocoa is standard risk; leather tanned in Morocco from imported hides needs the hides' origin; board made from imported pulp needs the fibre's origin.
What should exporters do now?
- This week: map your products. List what you sell to EU customers and flag the Annex I products from their Combined Nomenclature codes.
- Within two weeks: identify origins. For each product in scope, record the country of production of every commodity and its risk class in the Commission list.
- Before 30 December 2026: collect the data. Obtain from your suppliers the plot geolocation, production dates and proof of legality, organised by lot so that you can pass them to your customers.
- Before 30 December 2026: agree it in writing. Settle with each EU customer the data format, the transmission deadline and how they will share the reference numbers of their statements.
- Before 30 June 2027: small companies. If you are a micro or small undertaking exporting from the EU, prepare your own compliance; if you are a small primary producer, prepare the simplified declaration.
- Before 30 December 2027: watch the scope. Check whether the delegated act adds your products to Annex I.
Build these checks into your management system: purchasing procedure, supplier evaluation, lot-by-lot traceability and management review.
What mistakes should suppliers avoid?
Do not confuse certification with compliance: a sustainability label helps gather evidence but does not replace the due diligence statement. Do not wait for your customer's request: collecting geolocation from smallholders takes weeks. And do not assume a low-risk country spares you the data: traceability down to the plot is still required.
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