Regulation (EU) 2023/1115
EU Deforestation Regulation: which day is yours
Example data
- Who it applies to
- Anyone who places cattle, cocoa, coffee, oil palm, rubber, soya or wood products listed in Annex I on the EU market, exports them, or sells them on.
- The dates
- From 30 December 2026. An operator that is a natural person or a micro or small undertaking established as such by 31 December 2024 applies it from 30 June 2027. Not for the products in the Annex to Regulation (EU) No 995/2010: those keep 30 December 2026.
- The one thing to do
- Find your capacity and your products' codes. Then exercise due diligence and file the statement, or keep the records your capacity asks for.
Does the Regulation reach you?
Six answers, read by the same determination the portal runs. Nothing you pick is sent or stored.
Answer each question and the reading appears here.
The determination on its own page
Your capacity and your day
Two answers, read by the same determination the portal runs. Nothing you pick is sent or stored.
Pick one answer in each group.
- What the Regulation calls you
- Operator (Article 2, point (15))
- From
- 30 June 2027 Article 38(3): the later day, for an operator established as a natural person or a micro or small undertaking by 31 December 2024. It does not reach the products in the Annex to Regulation (EU) No 995/2010. For those the day is 30 December 2026, whatever your size.
- What you owe
- Exercise due diligence before each placing or export: collect the Article 9 information, then assess and mitigate the risk. File a due diligence statement in the information system and pass its reference number on (Articles 4 and 8 to 11).
- Your size
- As an SME or a natural person you owe neither the yearly public report of Article 12(3) nor the compliance officer and audit of Article 11(2).
- What the Regulation calls you
- Operator (Article 2, point (15))
- From
- 30 December 2026 Article 38(2).
- What you owe
- Exercise due diligence before each placing or export: collect the Article 9 information, then assess and mitigate the risk. File a due diligence statement in the information system and pass its reference number on (Articles 4 and 8 to 11).
- Your size
- As an SME or a natural person you owe neither the yearly public report of Article 12(3) nor the compliance officer and audit of Article 11(2).
- What the Regulation calls you
- Operator (Article 2, point (15))
- From
- 30 December 2026 Article 38(2).
- What you owe
- Exercise due diligence before each placing or export: collect the Article 9 information, then assess and mitigate the risk. File a due diligence statement in the information system and pass its reference number on (Articles 4 and 8 to 11).
- Your size
- As an SME or a natural person you owe neither the yearly public report of Article 12(3) nor the compliance officer and audit of Article 11(2).
- What the Regulation calls you
- Operator (Article 2, point (15))
- From
- 30 December 2026 Article 38(2).
- What you owe
- Exercise due diligence before each placing or export: collect the Article 9 information, then assess and mitigate the risk. File a due diligence statement in the information system and pass its reference number on (Articles 4 and 8 to 11).
- Your size
- Not an SME: a compliance officer at management level and an independent audit function (Article 11(2)), and a yearly public report (Article 12(3)).
- What the Regulation calls you
- Micro or small primary operator (point (15a))
- From
- 30 June 2027 Article 38(3): the later day, for an operator established as a natural person or a micro or small undertaking by 31 December 2024. It does not reach the products in the Annex to Regulation (EU) No 995/2010. For those the day is 30 December 2026, whatever your size.
- What you owe
- File a one-time simplified declaration with the Annex III information before placing or exporting, instead of a statement each time. Due diligence and its records still apply (Article 4a).
- Your size
- As an SME or a natural person you owe neither the yearly public report of Article 12(3) nor the compliance officer and audit of Article 11(2).
- What the Regulation calls you
- Micro or small primary operator (point (15a))
- From
- 30 December 2026 Article 38(2).
- What you owe
- File a one-time simplified declaration with the Annex III information before placing or exporting, instead of a statement each time. Due diligence and its records still apply (Article 4a).
- Your size
- As an SME or a natural person you owe neither the yearly public report of Article 12(3) nor the compliance officer and audit of Article 11(2).
- What the Regulation calls you
- Operator (Article 2, point (15))
- From
- 30 December 2026 Article 38(2).
- What you owe
- Exercise due diligence before each placing or export: collect the Article 9 information, then assess and mitigate the risk. File a due diligence statement in the information system and pass its reference number on (Articles 4 and 8 to 11).
- Your size
- As an SME or a natural person you owe neither the yearly public report of Article 12(3) nor the compliance officer and audit of Article 11(2).
- What the Regulation calls you
- Operator (Article 2, point (15))
- From
- 30 December 2026 Article 38(2).
- What you owe
- Exercise due diligence before each placing or export: collect the Article 9 information, then assess and mitigate the risk. File a due diligence statement in the information system and pass its reference number on (Articles 4 and 8 to 11).
- Your size
- Not an SME: a compliance officer at management level and an independent audit function (Article 11(2)), and a yearly public report (Article 12(3)).
- What the Regulation calls you
- Downstream operator (point (15b))
- From
- 30 December 2026 Article 38(2). Article 38(3) names operators only, so it does not move a trader's or a downstream operator's day.
- What you owe
- Collect and keep for five years who supplied you and whom you supplied, with the reference numbers where your supplier is an operator. Pass new risk information on at once (Article 5).
- Your size
- As an SME you do not register in the information system (Article 5(2)).
- What the Regulation calls you
- Downstream operator (point (15b))
- From
- 30 December 2026 Article 38(2).
- What you owe
- Collect and keep for five years who supplied you and whom you supplied, with the reference numbers where your supplier is an operator. Pass new risk information on at once (Article 5).
- Your size
- As an SME you do not register in the information system (Article 5(2)).
- What the Regulation calls you
- Downstream operator (point (15b))
- From
- 30 December 2026 Article 38(2).
- What you owe
- Collect and keep for five years who supplied you and whom you supplied, with the reference numbers where your supplier is an operator. Pass new risk information on at once (Article 5).
- Your size
- As an SME you do not register in the information system (Article 5(2)).
- What the Regulation calls you
- Downstream operator (point (15b))
- From
- 30 December 2026 Article 38(2).
- What you owe
- Collect and keep for five years who supplied you and whom you supplied, with the reference numbers where your supplier is an operator. Pass new risk information on at once (Article 5).
- Your size
- Not an SME: register in the information system before trading, and verify before selling on when there are substantiated concerns (Article 5(2) and (6)).
- What the Regulation calls you
- Trader (point (17))
- From
- 30 December 2026 Article 38(2). Article 38(3) names operators only, so it does not move a trader's or a downstream operator's day.
- What you owe
- Collect and keep for five years who supplied you and whom you supplied, with the reference numbers where your supplier is an operator. Pass new risk information on at once (Article 5).
- Your size
- As an SME you do not register in the information system (Article 5(2)).
- What the Regulation calls you
- Trader (point (17))
- From
- 30 December 2026 Article 38(2).
- What you owe
- Collect and keep for five years who supplied you and whom you supplied, with the reference numbers where your supplier is an operator. Pass new risk information on at once (Article 5).
- Your size
- As an SME you do not register in the information system (Article 5(2)).
- What the Regulation calls you
- Trader (point (17))
- From
- 30 December 2026 Article 38(2).
- What you owe
- Collect and keep for five years who supplied you and whom you supplied, with the reference numbers where your supplier is an operator. Pass new risk information on at once (Article 5).
- Your size
- As an SME you do not register in the information system (Article 5(2)).
- What the Regulation calls you
- Trader (point (17))
- From
- 30 December 2026 Article 38(2).
- What you owe
- Collect and keep for five years who supplied you and whom you supplied, with the reference numbers where your supplier is an operator. Pass new risk information on at once (Article 5).
- Your size
- Not an SME: register in the information system before trading, and verify before selling on when there are substantiated concerns (Article 5(2) and (6)).
At a glance
79requirements, each with the provision it rests on
8start a deadline clock
The dates, as amended twice
Read from the Regulation and the three acts that changed it, on 25 October 2026.
- 31 December 2020
Cut-off: land deforested after this day disqualifies a commodity
- 29 June 2023
In force; older timber keeps a transition
- 30 December 2026
Applies, after two postponements
- 30 June 2027
Applies to micro and small operators (Article 38(3))
- 30 December 2027
The products added to Annex I come into scope
- 31 December 2029
Older timber leaves the Timber Regulation
Annex I, commodity by commodity
A product is in scope only if its code is in Annex I. Codes in the last column join on 30 December 2027.
| Commodity | In Annex I | Joins on 30 December 2027 |
|---|---|---|
| Cattle | ex 0102, ex 0201, ex 0202, ex 0206 10, ex 0206 22, ex 0206 29, ex 1602 50 | ex 0206 21 00 |
| Cocoa | 1801, 1802, 1803, 1804, 1805, 1806 | None |
| Coffee | 0901 | 2101 11 00 |
| Oil palm | ex 1207 10 00, ex 1511, ex 1513 21, ex 1513 29, ex 2306 60 00, ex 2905 45, ex 2915 70, ex 2915 90, ex 3823 11 00, ex 3823 12 00, ex 3823 19, ex 3823 70 00 | ex 1516 20, ex 1518 00, ex 1520 00, ex 2905 16, ex 2905 17 00, ex 2905 19 00, ex 2915 39, ex 2916 15, ex 2916 19 10, ex 2921 19, ex 2923 90 00, ex 2924 19 00, ex 3401 11 00, ex 3401 20, ex 3824 99, ex 3907 29 |
| Rubber | ex 4001, ex 4005, ex 4006, ex 4007, ex 4008, ex 4011, ex 4012 90 30, ex 4013, ex 4015, ex 4017 | None |
| Soya | 1201 90 00, 1208 10, 1507, 2304 | None |
| Wood | ex 4401, ex 4402, ex 4403, ex 4404, ex 4405, ex 4406, ex 4407, ex 4408, ex 4409, ex 4410, ex 4411, ex 4412, ex 4413, ex 4414, ex 4415, ex 4416, ex 4417, ex 4418, ex 4419, ex 4420, ex 4421, ex 47, ex 48, ex 9401 31 00, ex 9401 41 00, ex 9401 61 00, ex 9401 69 00, ex 9401 80 00, ex 9401 91 90, ex 9403 30, ex 9403 40, ex 9403 50, ex 9403 60, ex 9403 91, ex 9406 10 00 | None |
ex: only to the extent the product is what the entry describes, such as made using oil palm.
Which countries are low risk
Article 29 has the Commission classify countries, and Commission Implementing Regulation (EU) 2025/1093 is that classification: 140 low risk, four high risk, and standard risk for the rest. It decides Article 13(1), which drops the risk assessment and the mitigation where every commodity was produced in a low-risk country.
- Low risk
- 140
- Every EU member state is on the list, so sourcing inside the Union is the simplified case.
- High risk
- 4
- Belarus, Myanmar (Burma), North Korea, Russia
- Standard risk
- The rest
- Not a list: Article 1(2) maintains a standard level for every country the Annex does not name, Brazil and Indonesia among them.
One country is printed differently: five language versions list the Central African Republic and the French version does not, with no corrigendum in any of them. We follow the five and say so, because Article 13(1) is a relief and being wrong about it costs a company the duties it owed.
The Annex, read on 24 October 2026
What the information system asks of you
Article 4(2) has the due diligence statement submitted through the Commission's information system, and Commission Implementing Regulation (EU) 2024/3084, as amended by Commission Implementing Regulation (EU) 2026/1565, is how that works. One of its rules is a deadline a company can miss.
- Article 5(1)A due diligence statement can be amended or withdrawn for 72 hours after its reference number appears, and no longer · as it stands in 2024/3084
- Article 5(2)The window closes early: once another statement of yours references it for grouping, it cannot be amended or withdrawn at all · as it stands in 2026/1565
- Article 8aStatements can be grouped: a new one referencing earlier reference numbers stands for them all · as it stands in 2026/1565
- Article 4aA micro or small primary operator submits a simplified declaration and gets a declaration identifier, not a reference number, and an update keeps the same identifier · as it stands in 2026/1565
- Article 3(c)The system is reached through EU Login, with an individual registration per user · as it stands in 2024/3084
Two of its rules are the Commission's rather than yours. From 15 October 2026 a statement goes to the authority of the state you are established in rather than the state of entry. By 30 December 2026 the Commission publishes what happens when the system is unavailable for more than an hour.
Both acts read on 24 October 2026. Nothing here is legal advice.
A certification scheme can feed the risk assessment as complementary information (Article 10(2), point (n)). It does not replace the due diligence or the statement.
Questions people ask
- Was the EUDR postponed again?
- Twice. Regulation (EU) 2024/3234 moved it a year, and Regulation (EU) 2025/2650 moved it a year again. It applies from 30 December 2026, and from 30 June 2027 to micro and small operators. On 25 October 2026 the Journal held no later act moving either day. Not for the products in the Annex to Regulation (EU) No 995/2010: those keep 30 December 2026 whatever the operator's size.
- Does an SME get until 30 June 2027?
- Not every SME. Article 38(3) gives the later day to an operator that is a natural person or a micro or small undertaking established as such by 31 December 2024. A medium undertaking applies it from 30 December 2026, and so does a micro trader or downstream operator, because the paragraph names operators only. And not for the products in the Annex to Regulation (EU) No 995/2010, sawn wood among them: those keep 30 December 2026 at any size.
- Operator, downstream operator or trader: which am I?
- The operator is the first to place a relevant product on the EU market or export it. A downstream operator places or exports products made from products already covered. A trader sells them on. One company can be all three, product by product.
- Is my product in scope?
- Only if its code is in Annex I. Delegated Regulation (EU) 2026/2102 removed cattle hides, skins and leather and narrowed wood, pulp and paper to leave out used products and single-use packaging. It adds soluble coffee and palm-based chemicals and soaps from 30 December 2027.
- What goes into the due diligence statement?
- Annex II: the operator, the HS code, the description and quantity, the country of production with the geolocation of every plot, and the operator's confirmation in set words. It is filed in the EU information system before placing or export, and its reference number travels down the chain.
Regulation (EU) 2023/1115 with Regulations (EU) 2024/3234 and 2025/2650 and Delegated Regulation (EU) 2026/2102, read on CELLAR on 25 October 2026: 79 requirements in the Official Journal's own words. EUR-Lex
The portal adds the Deforestation Regulation next
Its 79 requirements, the determination and the calendar are built, and its screens are not open yet. A trial opens the frameworks the pricing page lists today.
What it asks of you
79 requirements in 4 groups
Obligations
5- 3(a) Only deforestation-free products
- 3(b) Only products made under the producing country's law
- 3(c) Only products covered by a statement or a declaration
and 2 more
Duties
48- 4(1) Exercise due diligence before placing or exporting
- 4(2) Submit a due diligence statement first
- 4(3) Responsibility for compliance, and five years of records
and 45 more
Clauses
21- 1(1) Seven commodities and the products in Annex I
- 1(2) Products produced before entry into force are outside it
- 2(1) The relevant commodities
and 18 more
Deadlines
5- 37(1) The Timber Regulation is repealed
- 37(2) Older timber stays under the Timber Regulation for now
- 37(3) Then older timber has to meet Article 3
and 2 more