EUDR Due Diligence Complexity Checker

What is the EU Deforestation Regulation (EUDR)?

The EU Deforestation Regulation (Regulation EU 2023/1115) aims to reduce the EU's contribution to global deforestation and forest degradation. It prohibits placing on the EU market — or exporting from it — certain commodities and products that are not deforestation-free or that were not produced in accordance with relevant local laws.

Following two amendments — Regulation EU 2024/3234 (December 2024) and Regulation EU 2025/2650 (in force December 26, 2025) — the deadlines are now: December 30, 2026 for large and medium operators/traders; June 30, 2027 for micro and small enterprises not previously covered by the EU Timber Regulation (EUTR). Micro/small operators already covered by the EUTR must comply by December 30, 2026. The first operator placing products on the EU market must conduct full due diligence. Downstream operators and traders are largely exempt from the full statement requirement under the 2025 simplification.

The Seven EUDR Commodities

EUDR covers cattle, cocoa, coffee, palm oil, rubber, soy, and wood. Many derived products are also in scope: beef, leather, chocolate, cocoa butter, coffee extracts, palm oil derivatives, natural rubber products, soy oil and feed, timber, furniture, paper, and charcoal. Complexity varies by commodity — cocoa and palm oil often involve more fragmented, multi-country supply chains — and by the number of distinct production origins.

Operator vs Trader Under EUDR (2025 Simplification)

Under Regulation EU 2025/2650, the compliance burden has been significantly restructured:

• First operator (placing on EU market) — Bears full due diligence: collects geolocation, assesses risk, mitigates, submits a due diligence statement to the EU Information System. Highest compliance burden.
• Downstream operators and traders — No longer required to submit their own full due diligence statement. They must only collect the reference number of the due diligence statement from their direct supplier. Significantly reduced burden.
• Micro/small primary operators — May submit a simplified one-off declaration and may use postal addresses instead of GPS geolocation coordinates.

The Four Steps of EUDR Due Diligence (First Operator)

1. Information collection — Gather geolocation coordinates of every production plot (or postal address for micro/small), country of production, supplier details, proof of legality, and commodity volume.
2. Risk assessment — Evaluate the likelihood that the product is not deforestation-free or not produced in line with the country of production's laws, including country risk benchmarking.
3. Risk mitigation — Implement measures to bring any identified risk to a negligible level before placing products on the market.
4. Due diligence statement — Submit the statement to the EU Information System before placing goods on the EU market or exporting. The reference number from this statement is passed down the supply chain.