What is the EUDR?
The EUDR is an EU regulation, adopted in 2023, that makes access to the EU market conditional on proof. Any company that places one of the covered commodities or products on the EU market, or exports it from the EU, must be able to show that it was not produced on land deforested or degraded after 31 December 2020, that it was produced legally in its country of origin, and that the company carried out due diligence to establish both.
It replaces the EU Timber Regulation, extends the same logic from timber to six agricultural commodities, and asks for something the timber rules did not: the geolocation of the plots of land where the commodity was produced. The Commission expects it to cut emissions linked to EU consumption and production of these commodities by at least 32 million tonnes a year.
Which commodities and products are covered?
| Commodity | Examples of covered products | Where investors usually meet it |
|---|---|---|
| Cattle | Live cattle, beef, leather | Food producers, retailers, fashion and footwear |
| Cocoa | Beans, paste, butter, chocolate | Confectionery, food manufacturing |
| Coffee | Roasted and unroasted coffee | Food and beverage, hospitality supply |
| Oil palm | Palm oil and certain derivatives | Food, personal care, chemicals |
| Rubber | Natural rubber, tyres, gloves | Automotive suppliers, medical supplies |
| Soya | Beans, meal, oil | Animal feed, food manufacturing |
| Wood | Timber, furniture, pulp, paper, printed products | Packaging, furniture, construction, publishing |
The exact scope is set by product codes in Annex I of the regulation. A Commission delegated regulation adopted in 2026 adds further products, including soluble coffee, certain palm oil derivatives and frozen cattle tongues, from 30 December 2027.
EUDR timeline and deadlines
June 2023
June 2023
Regulation (EU) 2023/1115 enters into force
Originally due to apply from 30 December 2024.
December 2024
December 2024
First postponement
Regulation (EU) 2024/3234 delays application by a year. The EUDR Information System, where due diligence statements are filed, opens on 4 December 2024.
December 2025
December 2025
Second postponement and simplification
Regulation (EU) 2025/2650 sets the current dates and reduces obligations for downstream operators, traders and micro and small primary producers.
30 December 2026
30 December 2026
Applies to large and medium operatorsUpcoming
Also to micro and small operators already covered by the EU Timber Regulation.
30 June 2027
30 June 2027
Applies to micro and small operatorsUpcoming
The remaining micro and small operators come into scope.
30 December 2027
30 December 2027
Newly added products come into scopeUpcoming
Products added by Delegated Regulation (EU) 2026/2102.
Who must do what after the 2025 changes
The December 2025 amendment concentrated the work on the company that first places a product on the EU market or exports it. Companies further down the chain mostly keep records.
| Role | Obligations |
|---|---|
| Upstream operator: first places a product on the EU market, or exports it | Collects information including plot geolocation, assesses and mitigates risk, files a due diligence statement in the Information System before placing or exporting, and passes the statement’s reference number to its first buyer. |
| Micro or small primary operator in a low-risk country | Still carries out due diligence, but files a one-off simplified declaration instead of a statement per shipment. |
| Large downstream operator or trader | Registers in the Information System, keeps supplier and buyer records for five years, and verifies upstream due diligence only where it has substantiated concerns. |
| SME downstream operator or trader | Keeps supplier and buyer records for five years and reports concerns. No registration or verification. |
Countries are benchmarked as low, standard or high risk, which changes how much checking an operator must do. Enforcement sits with each member state’s competent authority, which can fine, confiscate products and revenue, and exclude a company from public procurement.
What the EUDR means for investors
Banks and investors are not obligated parties under the EUDR. The exposure runs through the companies they own and finance: a portfolio company that cannot evidence its supply chain risks fines, seized goods and lost access to its EU customers, and a due diligence statement filed in a rush looks, on paper, exactly like one backed by a working system. The difference only shows the next time a supplier changes or a regulator asks for the same proof.
Five questions to ask each portfolio company
- Do you place any of the seven commodities, or products made from them, on the EU market or export them from it?
- Which role do you hold for each product: upstream operator, downstream operator or trader?
- Do you hold geolocation and legality evidence for the plots behind each product, or rely on suppliers to?
- Does that evidence reconcile with your published deforestation commitments and certification claims?
- Is due diligence a repeatable system, or was it assembled for the first deadline?
