EU Deforestation Regulation (EUDR)

Overview

The EU Deforestation Regulation (EUDR) makes the placing of certain commodities and their derived products on the EU market — and their export from it — conditional on their not having caused deforestation. The instrument is Regulation (EU) 2023/1115 of 31.05.2023 (OJ L 150, 09.06.2023).

The Regulation is in force but not yet applicable. Its timetable has been postponed twice, most recently by Regulation (EU) 2025/2650 of 19.12.2025, in force since 03.01.2026. Much secondary commentary still prints the superseded dates; the dates that now govern are 30.12.2026 and 30.06.2027.

Scope and products

Seven commodities are covered: cattle, cocoa, coffee, oil palm, rubber, soya and wood. Annex I extends this to derived products listed by CN code — leather, chocolate, furniture, paper, printed books and tyres among them. Where a code carries the prefix “ex”, only part of it is in scope, so the exercise must be done line by line, not at product-family level.

Key obligations

Article 3 requires three cumulative conditions: the product must be deforestation-free, produced in accordance with the legislation of the country of production, and covered by a due diligence statement. The cut-off date is 31.12.2020. Under Article 9 the operator collects the geolocation coordinates of every plot of production and the production date range; Article 10 governs risk assessment and Article 11 mitigation where risk is not negligible. The statement is filed through the EU Information System before the goods are placed on the market or exported. Article 13 provides simplified due diligence for low-risk countries: information collection only, without risk assessment and mitigation.

Timeline

Four steps apply: 30.12.2026 for large and medium operators and traders, and for micro and small operators already subject to the EU Timber Regulation; 30.06.2027 for micro and small enterprises and natural persons; 30.12.2027 for products newly added to Annex I, which depends on the delegated act below completing scrutiny.

What this means for Turkish companies

The obligation attaches not to the Turkish seller but to the operator placing the goods on the EU market — in practice the EU importer or buyer. The operator cannot comply without upstream data, so the requirement reaches the Turkish supplier through the contract. Turkish exposure concentrates in furniture, wood products, paper and printed matter, leather goods, rubber products, chocolate and cocoa preparations.

Preparation has four parts: establishing by CN code whether the goods sit in Annex I; capturing geolocation and polygon data for the plots of origin — hardest where timber or cocoa is bought through traders; documenting legal production in the country of harvest; and evidencing the 31.12.2020 cut-off. Tying that data flow into the contract with the EU customer is the core of the work to complete before 30.12.2026.

Simplifications and the adopted delegated act

Regulation (EU) 2025/2650 lightened the load appreciably. It created a “downstream operator” category aligned with traders, with no due diligence verification where only already-compliant inputs are used. Only the first downstream operator or trader collects reference numbers, and the statement is submitted once per product, not annually. Micro and small primary operators may make a one-off simplified declaration, and postal addresses may replace geolocation for certain small producers.

On 04.05.2026 the Commission published its simplification review report, updated Guidance and FAQs, and draft acts on product scope and the Information System, projecting roughly 75% lower annual compliance costs than the original EUDR. The Information System was relaunched in June 2026, and on 13.07.2026 the Commission formally adopted both acts.

The delegated act is, however, not yet in force. It sits in a two-month scrutiny period before the Parliament and the Council, extendable to four, in which they may only veto it, not amend it. If unopposed it will be published in the Official Journal and the added products will apply from 30.12.2027. The act removes cattle hides, skins and leather, retreaded tyres, soybean seeds for sowing, vulcanised rubber conveyor and transmission belts, and aircraft and motor vehicle seats; it adds soluble coffee and coffee extracts, essences and concentrates, certain palm oil derivatives including soaps, and frozen bovine tongues. Waste, used and second-hand products, samples, packaging of any material including reusable packaging, marketing material and correspondence are expressly excluded. Removing leather and vehicle seats is material relief for Turkish leather and automotive-supplier exporters — but only once scrutiny clears. Until then the current Annex I stands.

Consequences of non-compliance

The Regulation bars placing on the EU market, or exporting, any product failing the three conditions. Supervision runs against the operator before the competent authorities of the Member States. For the Turkish seller the consequence is commercial rather than legal: a consignment without a filable due diligence statement stops at the customer, and a supplier that cannot provide data drops off the list. Securing the data flow contractually before 30.12.2026 is the real compliance instrument.

Related content

Reading EUDR alongside the CSDDD and LkSG records makes it easier to build one supplier file rather than three; the CBAM record covers the other large data demand from EU buyers. Our ESG and Sustainability focus sets out the whole picture.

Entry into force & amendment history

• 30.06.2027

  Small enterprises come in

  Application begins for micro and small enterprises and for natural persons.

• 30.12.2026

  Application begins

  Obligations take effect for large and medium operators and traders.

• 13.07.2026

  Delegated act adopted

  The Commission adopted the delegated act on product scope; it is in scrutiny and not yet in force.

• 03.01.2026

  Simplification in force

  Regulation (EU) 2025/2650 postponed the timetable and simplified the due diligence duties.