EUDR Compliance for Commodity Exports
The seven commodities in scope of the EU Deforestation Regulation, the geolocation and due-diligence obligations, and how to build an EUDR-ready shipment file that clears at import.
The EU Deforestation Regulation (EUDR) turns environmental compliance into a border-clearance issue for seven of the largest globally-traded commodities. From 30 December 2025, no in-scope shipment can enter the EU without a Due Diligence Statement identifying every plot of land the commodity came from. This guide walks through the scope, the data requirements and how to build a shipment file that clears customs on first presentation.
The seven commodities in scope
- Cattle - live animals, meat, edible offal, hides
- Cocoa - beans, paste, butter, powder, chocolate
- Coffee - green, roasted, extracts
- Oil palm - CPO, PKO, refined palm and their derivatives
- Rubber - natural rubber and derived products including tyres
- Soya - beans, meal, oil, and derived feed products
- Wood - lumber, panels, pulp, paper, printed products
Annex I of Regulation 2023/1115 lists the exact CN codes. Downstream products count too - a chocolate bar imported from Switzerland is in scope because it contains cocoa.
The Due Diligence Statement (DDS)
Every consignment placed on the EU market requires a DDS submitted via the EU Information System before customs release. The DDS contains:
- Operator identity and address
- HS/CN code and description of goods
- Quantity (net mass and, where applicable, volume)
- Country of production
- Geolocation of every plot of land - latitude/longitude to at least six decimal places, polygon for plots > 4 ha
- Date or time range of production
- Confirmation that due diligence was performed and risk is negligible
The deforestation cut-off date
EUDR bans commodities produced on land that was deforested after 31 December 2020. That is the fixed reference date - even if local law permitted the clearing. Satellite verification is via the EU's Copernicus programme and is retrospective; operators cannot rely on the absence of an alert to prove compliance.
Building an EUDR-ready shipment file
- Map the supply chain end to end. Every intermediary between farm and shipment must be documented - trader, mill, warehouse, forwarder.
- Collect geolocation at source. A farmer cooperative can provide plot coordinates via a smartphone app; a plantation should have a GIS file. Accept nothing less than six decimal places.
- Cross-check against forest cover baselines.Use Global Forest Watch or an equivalent dataset to check each plot was forested land as of the cut-off date.
- Assess legal compliance. Land tenure, labour law, indigenous consent, tax and export permits - all in the country of production.
- Submit the DDS. Upload via the EU Information System before customs release. Retain the DDS reference number and include it on the customs declaration.
Timeline and penalties
Application dates: 30 December 2025 for large and medium operators, 30 June 2026 for micro and small operators. Penalties: up to 4 percent of EU annual turnover, confiscation of goods, exclusion from public procurement, and criminal liability under national implementing law for wilful non-compliance.
Related commodity guides
For the affected commodities specifically, see the SSLT Global HS guides: coffee, natural rubber (EUDR), beef (EUDR), and the edible oils guide covering palm oil. Use the HS Code Lookup to confirm whether a specific CN code falls under Annex I.
Frequently asked questions
Which commodities are in scope of EUDR?#
Seven relevant commodities: cattle (and beef, leather), cocoa, coffee, oil palm, rubber, soya, and wood - plus a wide list of products derived from them (chocolate, tyres, tanned hides, palm-oil derivatives, printed paper). The full list is set out in Annex I of Regulation 2023/1115 by CN code.
When does EUDR apply?#
EUDR applies from 30 December 2025 for large and medium operators, and 30 June 2026 for micro and small operators. From those dates, any in-scope commodity or derived product placed on the EU market must be accompanied by a Due Diligence Statement (DDS) submitted via the Commission's Information System.
What geolocation data is required?#
Latitude and longitude of every plot of land where the commodity was produced, in decimal degrees with at least six decimal places. For plots larger than 4 hectares, a polygon (multiple coordinate pairs) is required. Data must be traceable back through every layer of the supply chain - from the export shipment to the individual farm or forest concession.
What is the due diligence obligation under EUDR?#
Three-step: (1) collect information including geolocation, quantity, date of production, and supplier chain; (2) risk-assess whether the commodity was produced on land deforested after 31 December 2020 and whether it complies with local laws (land tenure, labour, indigenous rights); (3) mitigate any identified risk before placing on the market. The DDS certifies these steps have been completed.
What happens if the DDS is missing or non-compliant?#
Customs authorities block release for free circulation. Penalties can reach 4 percent of the operator's EU annual turnover, plus confiscation of goods, exclusion from public procurement, and temporary ban from placing goods on the market. Repeat offenders face criminal liability under national implementing law.