EU deforestation rules apply Dec. 30: what U.S. companies selling into Europe need from suppliers of cocoa, coffee, soy, wood and rubber
Medium and large companies placing covered products on the EU market must show they are deforestation-free and legally produced, with geolocation data from origin. Recent changes put most of the burden on the first company to place goods on the market.
Article summary
- Why it matters: The EU Deforestation Regulation reaches far beyond Europe. Any company selling covered products into the EU, including U.S. manufacturers with European operations or customers, needs traceability back to the farm or forest plot. Suppliers that can’t provide geolocation data risk being shut out of EU supply chains after Dec. 30.
- What to do first: Work out your role. Determine whether your company is the first operator, a downstream operator or a trader for each product line in the EU.
- Map exposure now. Identify every SKU sold into the EU that contains a covered commodity, including packaging and pallets made of wood.
- Dec. 30, 2026
- EUDR applies to medium and large companies
- 7
- commodities covered: cattle, cocoa, coffee, palm oil, rubber, soy, wood
- Geolocation
- plot-level data required from origin
- DDS
- due diligence statement required before sale
On this page
The details
From Dec. 30, 2026, medium and large companies must ensure covered products placed on, made available in or exported from the EU market are:
- Deforestation-free
- Produced in line with the laws of the country of production
- Covered by a due diligence statement (DDS) submitted before the product is placed on the market or exported
Covered commodities: cattle, cocoa, coffee, palm oil, rubber, soy and wood, plus products that contain, were fed with or were made using them.
Recent simplifications, as summarized by Forvis Mazars:
- First-operator model. Full due diligence and the DDS generally fall on the operator that first places the product on the EU market.
- Downstream reliance. Downstream companies can, under certain conditions, rely on the original DDS by keeping its reference number and supplier and customer information.
- Small primary producers. Certain micro and small primary operators can use a simplified declaration in specific circumstances.
What the first operator must do: collect supplier information, obtain geolocation data for production plots, assess risk, mitigate identified risks and keep supporting documents.
How the deadline moved. The EU postponed the regulation for a second time through Regulation (EU) 2025/2650, setting the Dec. 30, 2026 date, according to a Mayer Brown analysis. Amendments introduced by the European Parliament in December 2025 substantially eased compliance for downstream companies and removed printed products such as books and newspapers from scope. Parliament also asked the European Commission for a simplification review by April 30, 2026; the Commission said it would make only “targeted tweaks to simplify implementation” rather than reopen the core text.
Scope changes under discussion. A draft update to the list of covered products was expected to include exemptions for samples, packaging, accessory materials, used and second-hand products, and waste, and some reports suggested palm-oil soap and instant coffee could be added. Stakeholders continue to push to exclude leather. Check the final list for your products.
The legality requirement is the hardest part. Products must comply with the laws of the country of production, and EU guidance covers eight legal areas, including land-use rights, labor rights, free prior and informed consent, and tax and customs rules. Mayer Brown’s authors argue that, in practice, this requires regular audits of producers, which makes certification schemes essential.
What a due diligence statement contains
Annex II of the regulation sets out what goes into a due diligence statement. In summary:
- The operator’s name, address and identifiers
- The product’s customs code, description and quantity
- The country of production
- Geolocation of every plot of land where the commodity was produced
- A statement that due diligence was carried out and found no or only negligible risk
The geolocation requirement is the one most suppliers struggle with. For larger plots, a polygon of the boundary is needed rather than a single point, under the regulation’s rules.
Penalties. Member states set penalties, but the regulation requires the maximum fine to be at least 4% of the company’s total annual EU turnover, alongside confiscation of products and revenue and temporary exclusion from public procurement. Enforcement will vary by member state.
What it means by category
| Category | Typical derived products | Hardest data to get |
|---|---|---|
| Cocoa and coffee | Chocolate, beverages, ingredients | Plot geolocation from smallholder farms |
| Palm oil and soy | Food ingredients, oleochemicals, animal feed | Traceability through crushers and refiners |
| Wood | Furniture, pallets, packaging, paper | Chain of custody across mills and converters |
| Rubber | Tires, hoses, seals | Smallholder traceability |
| Cattle | Leather, beef | Indirect suppliers and feedlots |
This is our assessment of where traceability is typically hardest.
Questions to ask your suppliers
- Which of the products you sell us contain EUDR commodities, and where were they produced?
- Can you provide plot-level geolocation data, or a DDS reference number from the operator who placed the product on the EU market?
- Who in your supply chain is the first operator, and have they started submitting statements?
- What is your plan if a source can’t provide the data by Dec. 30?
A readiness plan for the last weeks before Dec. 30
| When | What to do |
|---|---|
| Now | Confirm your role for each EU product line and list every SKU containing a covered commodity |
| Next 2–4 weeks | Send supplier questionnaires and request geolocation data or DDS references |
| Next 4–8 weeks | Escalate gaps; qualify alternative sources where suppliers can’t provide data |
| Before Dec. 30 | Test the EU information system with a sample statement; update contracts |
| January 2027 | Review blocked or delayed shipments and fix data gaps |
This plan is our suggestion and assumes you have not started. Teams further along should focus on the gaps.
What procurement teams should do
- Work out your role. Determine whether your company is the first operator, a downstream operator or a trader for each product line in the EU.
- Map exposure now. Identify every SKU sold into the EU that contains a covered commodity, including packaging and pallets made of wood.
- Add EUDR terms to contracts. Require geolocation data or DDS references, and allocate responsibility if a shipment is blocked.
- Prioritize alternative sources. Where a supplier can’t trace origin, qualify one that can before the deadline.
What to watch next
- Further EU guidance and FAQ updates before the deadline.
- Supplier readiness in high-risk origins.
- Enforcement approach by EU member state authorities in early 2027.
The bigger picture
EUDR joins forced-labor rules and supply chain due diligence laws in requiring origin-level data that many procurement systems weren’t built to hold. Investing in supplier data and traceability now pays off across all of them. For tools that help, see our supplier compliance software rankings.
Questions procurement teams are asking
When does the EU Deforestation Regulation apply?
From Dec. 30, 2026, for medium and large companies. A simplified regime applies to certain micro and small primary operators.
Which products does the EUDR cover?
Cattle, cocoa, coffee, palm oil, rubber, soy and wood, plus derived products that contain, were fed with or were made using them, such as chocolate, leather, furniture, paper and tires.
Does the EUDR apply to U.S. companies?
It applies to any company placing covered products on the EU market, making them available there, or exporting them from the EU, including subsidiaries and importers of U.S. companies.
What information goes into an EUDR due diligence statement?
Annex II of the regulation lists the operator's details, the product's customs code, description and quantity, the country of production, geolocation of every plot where the commodity was produced, and a statement that due diligence found no or negligible risk.
What are the penalties for breaching the EU Deforestation Regulation?
Member states set penalties, but the regulation requires maximum fines of at least 4% of a company's total annual EU turnover, plus possible confiscation of products and revenue and temporary exclusion from public contracts.
How we reported this
This analysis draws on 3 sources, listed below, and reflects figures as reported on October 7, 2026. The sections on why it matters and what procurement teams should do are Procurement Signal analysis. It is not legal or financial advice. See our editorial standards.
