EUDR 2026: A Guide for Importers and Exporters

EUDR 2026 – new obligations regarding import, export and transport

Check whether your goods are subject to the EUDR and how to prepare the necessary documentation to avoid delays in customs clearance.

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Key dates

30 December 2026
Large and medium-sized enterprises

30 June 2027
Micro and small enterprises

What is the EUDR?

The EUDR (European Union Deforestation Regulation) is a key component of the European Green Deal. Its aim is to minimise the European Union’s contribution to deforestation and forest degradation worldwide. The regulations require companies to prove that their products do not originate from areas deforested after 31 December 2020.

Key facts in 30 seconds

🌍

Purpose

Elimination of products linked to deforestation.

📦

Raw materials

7 main groups and hundreds of related products.

🛃

TRACES

Mandatory DDS declaration prior to clearance.

⚠️

Penalties

Up to 4% of annual turnover in the EU.

Products covered by the EUDR

🌳 Timber • ☕ Coffee • 🍫 Cocoa • 🌴 Palm oil • 🌱 Soya • 🛞 Rubber • 🐄 Cattle

Classification of countries by risk level (Benchmarking)

The benchmarking system is a mechanism used by the European Commission to assess countries (or parts thereof) in terms of the rate of deforestation and forest degradation. The assigned category determines the scope of due diligence obligations and the frequency of checks. The country classification list (published in May 2025) is available on the European Commission’s official website – check a country’s status here.

LOW RISK

Low risk

Simplified due diligence procedure.

There is no obligation to carry out a detailed risk assessment.
No obligation to implement mitigation measures.
Approximately 1% of entities are audited each year.

STANDARD RISK

Standard risk

A full due diligence process.

Mandatory risk assessment.
Restrictive measures, if necessary.
Audits of approximately 3% of entities.

HIGH RISK

High risk

The highest level of verification.

In-depth supplier analysis.
There is a high likelihood of an inspection.
Audits covering as many as 9% of entities and turnover.

What remains mandatory?

Geolocation of plots: GPS coordinates or polygons.
Proof of legality: evidence of compliance with the laws of the country of production.
DDS declaration: registration of each consignment in the TRACES system.
DDS reference number: required prior to customs clearance.

🛃

No special treatment

The ‘Low Risk’ status simplifies the procedure, but does not exempt you from the obligation to collect data and submit a DDS declaration.

Active monitoring: if a trader receives reliable information about a potential non-compliance issue with goods, they must immediately carry out a full due diligence procedure – even if the goods originate from a low-risk country.

POL-AGENT tip

It is essential for importers to keep a close eye on the European Commission’s ranking list. Imports from high-risk countries significantly increase the likelihood of inspections and require the implementation of robust supplier verification procedures.

How can you prepare your company for the EUDR?

Identify the goods covered by the regulation.
Verify the origin of the raw materials and their geographical location.
Assess the risk of deforestation.
Submit your DDS declaration via the TRACES system.
Please pass on the DDS number to the customs agency and the logistics department.

Importers

The importer is responsible for due diligence and for submitting the DDS declaration.

Exporters

Exporters must hold documentation confirming the conformity of the goods.

Transport and forwarding

Carriers and freight forwarders should obtain a DDS number prior to customs clearance.

Sanctions

Fines, confiscation of goods and a ban on trading within the EU.

EUDR checklist – what needs to be done right now?

Before the new requirements come into force, it is worth conducting an audit of your procurement, logistics and customs processes. The list below will help you check whether your company is ready for the EUDR.

1Check whether the goods are covered by the EUDR.

2Check the correct CN/TARIC codes.

3Determine the country of origin and the risk level.

4Obtain the geolocation data for the plots.

5Gather the documents confirming the legality of production.

6Carry out a deforestation risk assessment.

7Implement risk mitigation measures.

8Create an account and try out the TRACES system.

9Prepare the procedure for submitting the DDS.

10Arrange for DDS numbers to be forwarded to the customs agency.

11Train the procurement, logistics and compliance departments.

12Update your contracts with suppliers.

13Appoint a person responsible for the EUDR.

14Prepare the document archive.

💡 Tip: Obtaining data from suppliers usually takes the longest. It’s worth starting your preparations well in advance.

Key simplifications in the EUDR Regulation (Updated: April 2026)

Category	Type of simplification / Change	Benefit for the business
Further links in the chain	The ‘DDS Reference’ principle	Distributors and exporters do not need to carry out a new risk assessment; it is sufficient to provide the DDS number of the previous supplier in the EU.
Small plots	GPS point (< 0,5 ha)	For plots smaller than 0.5 ha, a single set of coordinates is sufficient instead of drawing the entire polygon.
Recycling	Exemption for 100% recycled content	Products made entirely from recycled materials (paper, rubber, retreaded tyres) are exempt from the EUDR.
Tyres	Retreading	Retreaded tyres (CN 4012) are classified as recovered goods and do not require a DDS declaration or geolocation.
Automotive	Fitted components	Tyres and leather parts fitted to finished vehicles are not subject to the EUDR (the vehicle’s CN code determines this, e.g. 8703).
Benchmarking	‘Low Risk’ countries	Exemption from stages 2 and 3 (risk analysis and mitigation). Only stage 1 (basic data and GPS) is required.
Supply chain	“Mass Balance” certification	The rules governing the blending of raw materials (e.g. rubber) have been clarified, making it easier to assign plot groups to production batches.
Digitisation	System interoperability	The ability to automatically import data from official national forest registers into the TRACES NT system.
Stocks	Transitional period	Flexibility for goods manufactured before the regulations come into force (29 June 2023) and clear rules on the disposal of stock placed on the market before December 2026.

Do you need assistance with the EUDR?

POL-AGENT supports importers, exporters and transport companies in preparing documentation and handling customs clearance in accordance with the EUDR.

EUDR UPDATE

EU Deforestation Regulation (EUDR) – status as of 27 September 2026

Key updates on product scope, implementation dates and operators’ obligations

IMPORTANT UPDATE
Since the publication of the original version of this guide, the EUDR framework has been amended and further clarified.
The section below summarises the most important changes that should be taken into account when preparing for EUDR compliance.

Basis of this update: amendments adopted in 2025 and 2026, including changes to the scope of products covered by EUDR
and updates concerning the operation of the EUDR Information System.

1. EUDR implementation dates

Large and medium-sized enterprises

30 Dec 2026

The main EUDR obligations will apply to large and medium-sized operators from this date.

Micro and small enterprises

30 Jun 2027

This is the general application date for most micro and small operators.

Important exception

30 Dec 2026

Applies to micro and small operators that were previously covered by the EU Timber Regulation (EUTR).

2. Changes to the scope of products covered by EUDR

Commission Delegated Regulation (EU) 2026/2102 amended Annex I to the EUDR.
The Regulation was published in the Official Journal of the European Union on 17 September 2026 and entered into force on 18 September 2026.

Products removed from the scope

certain raw bovine hides and skins, leather and related bovine products,
retreaded tyres,
certain articles of vulcanised rubber,
conveyor or transmission belts,
soybeans intended for sowing,
certain aircraft and motor vehicle seats.

Products added to the scope

instant coffee,
certain palm-oil derivatives,
frozen bovine tongues.

Important: the newly added products will become subject to EUDR obligations
from 30 December 2027.

Important: the amendment does not change the list of seven main commodities covered by EUDR: cattle, cocoa, coffee, oil palm, rubber, soya and wood. It changes the scope of certain products derived from those commodities.

3. Changes to responsibilities within the supply chain

One of the key changes is the simplification of the due diligence model. Responsibility for submitting a Due Diligence Statement (DDS) is primarily concentrated on the first operator placing the relevant product on the EU market or exporting it from the EU.

Producer / supplier
outside or inside the EU

→

FIRST OPERATOR
DDS / due diligence

→

Downstream operators
obligations depend on status

Following the amendments, entities operating further down the supply chain no longer have the same due diligence and DDS obligations as under the original model. The exact obligations depend on whether the company qualifies as an operator, downstream operator or trader, as well as on its size and role.

4. EUDR Information System

The current legislation and implementing acts refer to the EUDR Information System. The system is used, among other things, for submitting Due Diligence Statements and simplified declarations where applicable.

What does this mean in practice?
When preparing EUDR documentation, companies should use the current functionality of the EUDR Information System and the latest European Commission guidance. Older materials referring exclusively to “TRACES NT” may no longer reflect the current system.

5. Geolocation – important clarification

⚠️ Important note regarding older information

Older EUDR materials may refer to a 0.5-hectare threshold in the context of geolocation. This threshold should not be confused with the rules governing the representation of plot geolocation.

Under Article 2(28) of the EUDR, for plots of land with an area of more than 4 hectares used for the production of relevant commodities other than cattle, geolocation must be provided as a polygon describing the boundaries of the plot.

Plot up to 4 ha

Geolocation may be provided using the required geographical coordinates.

Plot above 4 ha

For the production of commodities other than cattle, a polygon describing the perimeter of the plot is required.

6. EUDR, transport, freight forwarding and customs clearance

The mere transport of a product does not automatically make a carrier or freight forwarder an “operator” under the EUDR. The actual role of the company within the supply chain is decisive.

Before an import customs declaration is submitted, it is worth verifying:

the CN code of the imported product,
whether the product is included in the current Annex I to the EUDR,
the company’s status and role in the supply chain,
the country of production and origin of the relevant commodity,
the required geolocation data,
whether a DDS or another declaration is required,
the reference number / identifier of the relevant declaration, where required.

For companies using customs clearance services, this means that EUDR procedures should be properly integrated into the preparation of import and export documentation.

7. EUDR 2026 – quick checklist for importers

✓ Check the CN code of the product

✓ Check the current scope of Annex I

✓ Determine your role in the supply chain

✓ Determine the applicable EUDR implementation date

✓ Verify the country of production and risk classification

✓ Prepare the required geolocation data

✓ Verify the applicable DDS requirements

✓ Integrate EUDR requirements into the customs process

POL-AGENT

Need assistance with imports of products covered by EUDR?

POL-AGENT supports businesses with customs clearance and formalities related to international trade. For products covered by EUDR, we can assist with the organisation of the import process and verification of the required documentation.

CONTACT POL-AGENT

Information updated: 27 September 2026.
This update is provided for information purposes only and does not constitute legal advice. For individual transactions, the current wording of the EUDR, its Annexes and the latest European Commission guidance and communications should always be checked.