In this article, learn about:
- Why 71 days is not enough time to start EUDR compliance from scratch
- Which commodities and derived products fall within EUDR's scope
- What the 3-step due diligence process requires from operators in practice
- How country risk classifications change your documentation burden
What EUDR Requires and Why the Timeline Is Short
The EU Deforestation Regulation (EUDR) requires any business placing certain commodities or derived products on the EU market to prove those goods have not contributed to deforestation after 31 December 2020. It covers operators who import into the EU and traders who move regulated goods within it.
The compliance deadline for large and medium operators is 30 December 2026. Meeting it means tracing each regulated product to the exact plot of land where it was produced, running a documented risk assessment, and filing a Due Diligence Statement (DDS) via the EU's TRACES system before placing goods on the market. Without a valid DDS reference number, goods cannot legally enter the EU.
What makes the timeline tight is the data, not the process. Plot-level geolocation data rarely exists in standard procurement systems. Collecting it means engaging every tier of the supply chain, and for products sourced from standard or high-risk countries, that engagement needs to be thorough and documented. 71 days remain before the 30 December deadline. That is enough time to complete a process already underway. It is not enough time to start from scratch.
Which Products Are in Scope
EUDR covers 7 core commodities and the derived products made from them. The scope reaches further than most businesses expect when they first look at it.
| Commodity | Examples of derived products in scope |
|---|---|
| Cattle | Beef, leather goods, hides |
| Cocoa | Chocolate, cocoa butter, confectionery |
| Coffee | Roasted and soluble coffee |
| Palm oil | Cooking oils, soaps, cosmetics, palm kernel products |
| Rubber | Tyres, rubber gloves, footwear |
| Soy | Animal feed, tofu, soy-based food products |
| Wood | Furniture, paper, printed packaging, timber, charcoal |
Scope is not determined only by primary ingredients. A cardboard box made from wood pulp is within scope. A piece of furniture with leather upholstery may carry obligations under both cattle and wood. Businesses should check their full product portfolio against Annex I of the regulation before assuming any category is clear.
The Compliance Deadlines
2 dates apply depending on company size:
- 30 December 2026 for large and medium operators
- 30 June 2027 for micro and small enterprises (SMEs)
The regulation's reference date is fixed regardless of when a compliance programme starts. Products must be traceable to land where no deforestation occurred after 31 December 2020. Beginning late does not reduce the volume of data required or shorten the lookback window.
How Country Risk Changes Your Obligations
In May 2025, the European Commission published a benchmarking system classifying every country as low, standard, or high risk based on deforestation trends and legal frameworks. Risk level determines how much due diligence an operator must perform.
| Risk level | Countries included | Due diligence requirement |
|---|---|---|
| Low risk | EU member states, UK, USA, Canada, China, Japan, Australia and South Africa among others | Simplified obligations |
| Standard risk | Brazil, Indonesia, Malaysia among others | Full due diligence required |
| High risk | Russia, Belarus, Myanmar, North Korea | Enhanced scrutiny and documentation |
Low-risk classification reduces burden but does not remove it. Operators sourcing from low-risk countries still need to confirm the product's origin and keep records. The Commission published its first classification list in May 2025. Country assignments are subject to review as updated FAO forest data becomes available, so risk assignments for specific sourcing regions should be confirmed against the current official list before the December deadline.
What Compliance Requires: 3 Steps
1. Information Collection
Operators must gather product data, supplier details, and precise geolocation for every production plot in the supply chain. The format requirements are specific. Plots larger than 4 hectares require polygon coordinates in GeoJSON format; plots of 4 hectares or under can use either a polygon or a single GPS point. Incomplete or inaccurate coordinates are the leading cause of DDS rejections, and fixing them after submission adds delay to an already tight process.
2. Risk Assessment
Using the collected data, operators assess whether there is a risk that the product is linked to deforestation. Country classification provides a starting point, but the assessment must also account for specific supply chain knowledge, concerns about particular production regions, and any indigenous land rights issues in the area. It must be documented and retained.
3. Due Diligence Statement Submission
The DDS is submitted via the EU's TRACES NT system before the product is placed on the EU market. Each shipment requires its own statement, and the resulting reference number is required for customs clearance. Goods arriving without one are stopped at the border.
What Non-Compliance Costs
Fines can reach 4% of a company's total annual EU turnover, plus product confiscation, exclusion from public procurement, and temporary market bans. Enforcement sits with national authorities in each EU member state. The financial exposure for businesses with significant EU revenue is material, and the reputational risk in markets where sustainability credentials matter commercially is harder to quantify.
What the Remaining Window Is For
The hardest part of EUDR compliance is upstream data. Geolocation coordinates for production plots are not part of standard supplier onboarding documents. In commodity supply chains with multiple tiers between operator and farm, collecting that data requires engagement with suppliers who may never have been asked for it before. Those conversations take time, and correcting coordinate errors after an initial pass takes more.
Businesses that started this process earlier in the year are using the remaining 71 days to close gaps and validate data before DDS submissions begin. For businesses still working through the traceability data collection, the priority is moving at pace now. The European Commission's EUDR implementation portal is the authoritative source for current guidance, country risk classifications, and TRACES NT access.
The trading partner infrastructure that governs how goods move through European retail supply chains is a separate obligation, and one that can be addressed in parallel. For suppliers building or expanding EU retail connections alongside EUDR preparation, SPS Commerce can get the EDI side established quickly. The EUR network covers retailer connections, document exchange, and spec management across major European accounts, so suppliers are not managing two separate timelines independently. Both requirements can be met before December.