What products does the EUDR cover?

EUDR covers seven commodities and their derived products: cattle (including leather and beef), cocoa (including chocolate), coffee, oil palm (including palm oil), rubber, soya (including soy meal and soy oil), and wood (including timber, paper, printed products, charcoal, and furniture). The regulation covers both raw commodities and processed products.

What is the December 2020 cutoff date?

EUDR prohibits placing products on the EU market if they are linked to land that was deforested or degraded after December 31, 2020. Companies must demonstrate through due diligence that their products are 'deforestation-free' — meaning no deforestation or forest degradation occurred after this date on the land where the commodity was produced.

Does EUDR apply to non-EU companies?

EUDR applies to any operator or trader placing covered products on the EU market or exporting them from the EU, regardless of where the company is headquartered. Non-EU producers are indirectly affected as their EU buyers must conduct due diligence on the products they import. This creates de facto requirements for suppliers globally.

European Deforestation Regulation (EUDR)

What Is the EUDR?

The EU Deforestation Regulation (Regulation 2023/1115), adopted in June 2023, prohibits the placement on the EU market — and export from the EU — of certain commodities and products linked to deforestation or forest degradation. It replaces the weaker EU Timber Regulation and significantly expands the scope of commodities covered and the rigor of due diligence required.

The EUDR reflects the EU's commitment to reducing its global deforestation footprint. The EU is a major consumer of forest-risk commodities, and consumer-driven deforestation is a leading cause of biodiversity loss and greenhouse gas emissions.

Who It Applies To

Operators: Companies that first place covered products on the EU market or export them. This includes importers, manufacturers, and producers.
Traders: Companies that make covered products available on the EU market in the course of commercial activity (distributors, retailers).
SMEs: Simplified due diligence requirements for small and medium enterprises that are traders (not operators).

The law applies regardless of where the company is headquartered — what matters is whether the product enters the EU market.

Key Requirements

Due diligence obligation: Companies must exercise due diligence before placing covered products on the EU market:

Information collection: Gather geolocation data of the land where the commodity was produced, including GPS coordinates of all plots of land. This is the most novel and challenging requirement.
Risk assessment: Assess the risk that the product is linked to deforestation or forest degradation after December 31, 2020. Consider country risk classification (low, standard, high risk — determined by European Commission), complexity of the supply chain, and presence of indigenous peoples and local communities.
Risk mitigation: If risk is identified, take adequate measures to mitigate it — this may include independent audits, satellite monitoring, supplier verification, and isotope testing.

Deforestation-free requirement: Products must be produced on land that was not subject to deforestation or forest degradation after December 31, 2020. "Deforestation" means conversion of forest to agricultural use. "Forest degradation" means harvesting that is not sustainable.

Legality requirement: Products must be produced in accordance with the relevant legislation of the country of production — including land use rights, environmental protection, labor rights, and trade regulations.

Traceability requirement: Full supply chain traceability back to the plot of land where the commodity was produced, with geolocation coordinates.

Covered Commodities and Products

Commodity	Example Products
Cattle	Beef, leather, gelatin
Cocoa	Chocolate, cocoa butter, cocoa powder
Coffee	Roasted coffee, instant coffee
Oil palm	Palm oil, palm kernel oil, oleochemicals
Rubber	Natural rubber, tires, latex
Soya	Soybean oil, soy meal, tofu
Wood	Timber, paper, furniture, charcoal, printed products

Timeline

June 2023: EUDR entered into force
December 2024: Originally planned to apply to operators and traders (postponed)
December 2025: New application date for large operators and traders (after postponement)
June 2026: Application date for SME traders
Ongoing: European Commission to publish country benchmarking (low, standard, high risk)

Compliance Steps

Product scope assessment: Identify which of your products fall under EUDR commodity categories
Supply chain mapping: Map supply chains back to production origins with geolocation data
Due diligence system: Establish or enhance due diligence processes for covered commodities
Geolocation data collection: Implement systems to collect GPS coordinates of production plots from suppliers
Risk assessment: Evaluate deforestation risk using satellite data, country risk classifications, and supply chain complexity
Verification: Verify deforestation-free status using satellite monitoring, field audits, and third-party certification
Record-keeping: Maintain due diligence records for 5 years
Reporting: Submit due diligence statements through the EU information system

Penalties

Fines: Up to 4% of total annual EU-wide turnover
Product confiscation: Authorities can seize non-compliant products
Market exclusion: Temporary prohibition from placing products on the EU market
Public naming: Publication of non-compliant companies
Revenue confiscation: Confiscation of revenues from transactions involving non-compliant products

How Council Fire Can Help

Council Fire helps companies navigate EUDR compliance — from supply chain mapping and geolocation data collection through risk assessment systems and due diligence documentation. Contact us for EUDR compliance support.