Climate & nature
Regulation (EU) 2023/1115
Deforestation rules
EU Deforestation Regulation
Coffee, cocoa, soy, palm oil, cattle, rubber, wood — if it grew on land deforested after 2020, it should not be sold in the EU.
Does this hit me?
Your chocolate or coffee should, over time, be less tied to freshly cleared forest. Prices and some brands may shuffle as supply chains clean up.
Check in the wizardPick a country in the header to see who enforces this at home. Union text is not the last word for directives.
Next switch-on: in 3 months · 30 Dec 2026 — Deforestation rules — staged application
How it rolls in
Jun 2023
Entered into force.
2025–2026
Application dates shifted to give systems time.
Why it exists
EU consumption drives forest loss abroad. The law asks for plot-level proof instead of vague 'sustainable' logos.
What actually changes
- Operators must collect geolocation of plots and a due-diligence statement.
- Products linked to deforestation or illegality cannot be placed on the market.
- Countries are benchmarked by risk, which changes how deep checks go.
How it hits you
Your chocolate or coffee should, over time, be less tied to freshly cleared forest. Prices and some brands may shuffle as supply chains clean up.
For citizens
What this does to everyday life
Rights, bills, and what you can ignore. You are usually not the one who files — companies and states are.
Coffee, chocolate, sofas, tyres
The EU does not want those goods grown on land deforested after 2020. Over time, supermarket shelves should tilt toward traceable lots.
Prices and brands
Cleaning a chain costs money. Some cheap lines may vanish; others will relabel. That is a consumer-price story, not a form you fill in at checkout.
Rights you actually get
- No personal due-diligence statement. Operators (importers/traders) file those.
Costs and trade-offs
- Possible price rises or gaps for some tropical commodities if supply is tight.
What you can do
- Ask brands whether lots are EUDR-ready. NGOs and journalists will test claims harder than a QR code on a bar.
What you can ignore
- You do not geolocate your morning coffee.
- Eating chocolate is not illegal. Selling deforested-plot cocoa in the EU is the problem.
If something goes wrong
Consumer protection for misleading green claims; customs and environment authorities for the regulation itself.
More citizen notes across files: For people
Heard this? Not quite.
Claim: Small farmers are locked out of Europe forever.
The rule is about land conversion after 2020, not farm size. Cooperatives and simplified SME paths exist — messy in practice, but that is the design.
Latest official statements
All EU NewsNo tagged Commission, Parliament or Council statement in the current feeds.
Board one-pager
Board one-pager
Who this is for: EU manufacturers, energy and importers. Regulation (EU) 2023/1115. in 3 months · 30 Dec 2026.
Scope
- You place cattle, cocoa, coffee, oil palm, rubber, soya, wood — or listed derived products such as leather, chocolate, furniture, tyres — on the EU market.
First 90 days
- Now: Classify SKUs against the commodity/product annex.
- Now: Decide operator vs trader for each flow.
- 90 days: Collect geolocation and legality evidence; test a due-diligence statement in the information system.
Penalties: National penalties, seizure, and exclusion from public procurement can apply. Maximums are meant to be dissuasive (including turnover-based).
For companies
How to stay on the right side of this file
Practical order of work, not a substitute for counsel. Operators and traders placing listed commodities and derived products on the EU market, or exporting them.
You are probably
Operators and traders placing listed commodities and derived products on the EU market, or exporting them.
Effort
A scoped programme this year beats a scramble at the apply-date.
Budget
SME: owner time plus one honest vendor. Large: a named lead, not a taskforce slide.
Roles in this file
The same company can wear more than one hat. Classify before you buy a tool.
Regulatory
This pack names Regulatory as an owner of early work.
Classify SKUs against the commodity/product annex.
Legal
This pack names Legal as an owner of early work.
Decide operator vs trader for each flow.
Sourcing + IT
This pack names Sourcing + IT as an owner of early work.
Collect geolocation and legality evidence; test a due-diligence statement in the information system.
Are you in scope?
This year's work- You place cattle, cocoa, coffee, oil palm, rubber, soya, wood — or listed derived products such as leather, chocolate, furniture, tyres — on the EU market.
Usually not, if
- Retailers who are not operators in the legal sense may still be traders with lighter duties — map your role.
First moves
- NowClassify SKUs against the commodity/product annex.Regulatory
- NowDecide operator vs trader for each flow.Legal
- 90 daysCollect geolocation and legality evidence; test a due-diligence statement in the information system.Sourcing + IT
- Buy from operators who already file statements. Do not try to map the Amazon from a two-person office.
If you skip this
- Mixing compliant and non-compliant lots in one tank or warehouse without a system that preserves the claim.
Done looks like
- Plot geolocation.
- Production period.
- Legality checks.
- Due-diligence statements.
Keep this evidence
- Plot geolocation.
- Production period.
- Legality checks.
- Due-diligence statements.
- Risk assessments.
Ask vendors
- Will you provide plot geolocation and a transferable due-diligence pack?
Where programmes usually break
- Mixing compliant and non-compliant lots in one tank or warehouse without a system that preserves the claim.
Call counsel when
- National penalties, seizure, and exclusion from public procurement can apply. Maximums are meant to be dissuasive (including turnover-based).
- A supervisor letter, a dawn information request, or a deal that warrants this file.
Enforcement
National penalties, seizure, and exclusion from public procurement can apply. Maximums are meant to be dissuasive (including turnover-based).
Competent authorities in Member States; customs at the border.
Need a stack, not one file? Open the company desk
Professional briefing
Legal architecture and duties
For counsel, compliance, and policy teams. Not advice. The Official Journal still wins.
- Instrument
- Regulation
- Legal basis
- Art 192 TFEU · Regulation (EU) 2023/1115
- Application
- In force June 2023. Application was postponed: 30 December 2025 for large/medium operators, 30 June 2026 for micro and small (confirm any further delay in the OJ before go-live). Transitional stocks rules exist.
A prohibition on placing on the Union market, or exporting from it, listed commodities and derived products that are not deforestation-free (cut-off 31 December 2020) and not legally produced. Operators must file a due-diligence statement in the information system, with geolocation of plots. This is plot-level traceability, not a corporate ESG narrative. The 2024/2025 delay was political; the architecture did not become ‘risk-based only’.
How the file is built
Commodities
Cattle, cocoa, coffee, oil palm, rubber, soya, wood, and listed derived products (leather, chocolate, furniture, tyres, printed paper, etc.). Annex I is the law.
Three duties
Information collection (including geolocation), risk assessment, risk mitigation to no or only negligible risk. Then a DDS in the IT system.
Operators vs traders
Operators place on the market or export. Downstream large traders have operator-like duties; SMEs further down may rely on upstream reference numbers — with residual checks.
Operators
| Role | Who | Core duties |
|---|---|---|
| Operator | Places relevant products on the market or exports them. | Full due diligence + statement. Keep records 5 years. |
| Trader | Makes available on the market in the supply chain. | Scaled; non-SME traders ≈ operators. |
| Competent authority | National, with a minimum inspection rate by country-risk tier. | Checks, corrective actions, penalties, seizure. |
Scope
Placing on the EU market and export from the EU. Production can be anywhere, including inside the Union (EU farms are not exempt from legality and deforestation-free tests).
In
- Annex I products containing, fed with, or made from the seven commodities.
- Deforestation and forest degradation as defined (FAO-aligned, with a degradation definition that wood lawyers fight over).
- Legality under the country of production’s law (land use, labour, human rights, tax, FPIC where applicable).
Out, or narrower than assumed
- Products not in Annex I (even if environmentally relevant).
- Packaging material used exclusively as packaging to support, protect or carry another product — a narrow carve-out.
- Recycled content in some wood products — read the article, do not generalise.
Operative provisions
| Anchor | Rule | What it does in practice |
|---|---|---|
| Art 3 | Prohibition: not deforestation-free, or not legally produced, or not covered by a DDS. | A missing statement is as fatal as a deforested plot. |
| Art 9–11 | Information, assessment, mitigation. Geolocation of all plots. Country benchmarking affects scrutiny, not the duty to be deforestation-free. | ‘Low-risk country’ is not a free pass. |
| Penalties | Maximum fine of at least 4% of EU turnover, seizure, confiscation of revenue, temporary prohibition. | Customs and environmental authorities will both sit on this. |
Secondary law and guidance
- Commission information system (register of statements).
- Country benchmarking implementing acts.
- Guidance on geolocation, legality, and product scope — useful, not a substitute for Annex I.
National layer. Competent authorities, customs, penalties, and criminal overlays are national. Inspection percentages are a Union floor by risk tier.
How it sits with other files
Enforcement and private rights
Who
National competent authorities + customs. Commission runs the IT system and benchmarking.
Tools
Document and field checks, satellite, seizure, 4% turnover-class fines, prohibition to deal.
Private rights
Competitors and NGOs will use unfair-commercial-practice and due-diligence publicity; standing varies.
Risk register
| Risk | Signal | Control |
|---|---|---|
| Mass-balance wishful thinking | Commodity trader offers ‘EUDR-ready mix’ without plot IDs | No buy without geolocation that can sit in a DDS. |
| Annex I miss | Leather seats, cocoa butter, or rubber seals not in the product graph | BOM review against Annex I with trade counsel. |
| Statement factory without assessment | DDS filed on a template with empty risk file | Documented Art 10 assessment before submit. |
Open issues
- Whether further delays or simplifications land in 2026.
- Plot-level data for smallholders and cadastral gaps.
- Definition fights on ‘forest degradation’ for wood.
Primary sources
Coffee, cocoa, soy, palm oil, cattle, rubber, wood — if it grew on land deforested after 2020, it should not be sold in the EU.
You feel it now
This is a this-year file.
Next
Application delayed then staged; large operators first
Where it lands
| Channel | People | Companies |
|---|---|---|
| Plot-level traceability | Your chocolate or coffee should, over time, be less tied to freshly cleared forest. Prices and some brands may shuffle as supply chains clean up. | Geolocation of plots (and polygons for larger plots) is the operational shock. Mass-balance folklore is not enough. |
| Smallholder inclusion | Your chocolate or coffee should, over time, be less tied to freshly cleared forest. Prices and some brands may shuffle as supply chains clean up. | If your chain cannot collect plots without dropping small farmers, you have a sourcing-redesign problem, not only an IT one. |
| Benchmarking | Your chocolate or coffee should, over time, be less tied to freshly cleared forest. Prices and some brands may shuffle as supply chains clean up. | Country risk tiers change how deep due diligence goes. High-risk origins need more than a portal login. |
Who gains
Forests and communities at the forest frontier; compliant producers.
Who pays
Operators placing listed commodities on the EU market.
Who pays
Operators placing listed commodities on the EU market.
Who benefits
Forests and communities at the forest frontier; compliant producers.
Read the official text