The EU Deforestation Regulation (EUDR), Regulation (EU) 2023/1115, requires seven commodities and their derived products to be deforestation-free and legally produced before they can be placed on the European market. The baseline is fixed: land deforested after 31 December 2020 cannot supply covered goods to the EU.
After two postponements, the obligations apply from 30 December 2026 for medium and large operators and traders, and from 30 June 2027 for micro and small operators established by 31 December 2024, as set by Regulation (EU) 2025/2650 of 19 December 2025. India is benchmarked a low-risk country, which simplifies the due diligence that EU buyers of Indian coffee, rubber, cocoa, leather and wood products must run, without removing it.
What is the EUDR and why the EU introduced it
Consumption inside the European Union drives deforestation far beyond its borders, through imported beef, cocoa, coffee, palm oil, rubber, soya and timber. The EUDR replaces the older EU Timber Regulation with a much wider rule: any covered commodity or product placed on the EU market, or exported from it, must be proven deforestation-free against the 31 December 2020 cut-off and produced in compliance with the laws of the country of production.
The proof is not a certificate purchased once a year. It is plot-level evidence: satellite-checkable geolocation coordinates of every plot of land where the commodity was produced, carried through the supply chain into a due diligence statement filed in the EU information system before goods cross the border.
Which commodities and products the EUDR covers
| Commodity | Derived products include |
|---|---|
| Cattle | Beef, leather and hides |
| Cocoa | Cocoa butter, chocolate |
| Coffee | Roasted and decaffeinated coffee |
| Oil palm | Palm oil, glycerol and derivatives |
| Rubber | Tyres, tubes, rubber articles |
| Soya | Soya beans, flour and meal |
| Wood | Timber, furniture, pulp and paper |
Coverage follows the combined nomenclature codes listed in Annex I, so the CN classification of each product decides whether it is in scope. Printed products such as books and newspapers were removed from Annex I by the 2025 amendment. A draft delegated act of May 2026 would further remove leather and retreaded tyres and add soluble coffee and certain palm oil derivatives, but it has not been adopted, so leather remains in scope today.
The EUDR timeline after two delays
| Stage | Medium and large operators | Micro and small operators |
|---|---|---|
| Original, Regulation (EU) 2023/1115 | 30 December 2024 | 30 June 2025 |
| First delay, Regulation (EU) 2024/3234 | 30 December 2025 | 30 June 2026 |
| Current, Regulation (EU) 2025/2650 | 30 December 2026 | 30 June 2027 |
Two dates never moved: the regulation has been in force since 29 June 2023, and the deforestation cut-off stays at 31 December 2020. Land cleared after that date is already off-limits for covered goods regardless of when the filing obligations start, which is why supply chains are being mapped now rather than in December 2026.
The core duties: geolocation, legality and the due diligence statement
The obligations fall on the operator, the business that first places a covered product on the EU market or exports it. Before any covered shipment, the operator must:
- Collect plot-level information. The geolocation of every plot of land where the commodity was produced, as latitude and longitude to at least six decimal digits. Plots over four hectares need polygon coordinates describing the perimeter, except for cattle.
- Verify deforestation-free status and legality. Evidence that the land was not deforested after 31 December 2020 and that production complied with the law of the country of production.
- File the due diligence statement. One statement per first placing on the market, lodged in the EU information system. The system issues a reference number that downstream businesses pass along instead of filing fresh statements, a simplification confirmed by the 2025 amendment.
The information system runs on the Commission’s TRACES platform and has operated since 4 December 2024. It entered a read-only window on 16 February 2026 and reopens in June 2026 with the amended features, so registrations and filings resume well ahead of the December date.
A non-EU producer is not directly bound by the regulation, but every input above comes from the producer side: the plot coordinates, the land records and the chain of custody. Exporters who hand their EU buyers a complete, verifiable data package keep their place in the chain; exporters who cannot are the easiest risk for a buyer to remove.
India is low risk: what that changes and what it does not
Commission Implementing Regulation (EU) 2025/1093 of 22 May 2025 benchmarked every country, and India is classified low risk. An EU operator sourcing exclusively from low-risk countries may run the simplified due diligence of Article 13: the risk assessment and risk mitigation steps fall away unless the operator becomes aware of information pointing to non-compliance.
What never falls away is the information duty. Plot geolocation, polygons over four hectares, the 2020 baseline evidence and legality records are required from low-risk countries exactly as from high-risk ones. Low risk also lowers the inspection burden: authorities must check at least 9 percent of operators sourcing from high-risk countries and 3 percent for standard risk, but only 1 percent for low-risk origins such as India. Micro and small primary producers established in a low-risk country gain a further easement from the 2025 amendment: a one-time simplified declaration instead of a due diligence statement, with a postal address accepted in place of coordinates. Low risk makes Indian sourcing cheaper to verify than competing origins, an advantage Indian exporters can press, but only with the data package ready.
Penalties under the EUDR
Article 25 requires Member States to set maximum fines of at least 4 percent of the operator’s total annual Union-wide turnover in the year before the fining decision, alongside confiscation of the products and of the revenues gained, and temporary exclusion of up to 12 months from public procurement and public funding. Non-compliant shipments can be denied entry outright, so the commercial penalty arrives well before any fine: the goods simply stop moving.
What exporters in India should do before 30 December 2026
- Map the portfolio against Annex I. Identify every product whose CN code is covered, from green coffee to leather goods and wooden furniture.
- Geolocate the production plots. Latitude and longitude to six decimal digits for every plot, polygons where plots exceed four hectares.
- Assemble the 2020 baseline evidence. Land records and satellite history showing no deforestation after 31 December 2020, plus legality documentation.
- Build the traceability chain. Batch-level records connecting each shipment back to its plots, so the EU operator can file an accurate due diligence statement.
- Watch the scope. The Commission’s May 2026 simplification package carries updated guidance, an updated FAQ and a draft delegated act that would move leather out of scope and soluble coffee in; portfolio mapping should be rechecked when it is adopted.
- Use the runway. The 30 December 2026 date is the filing deadline, not the preparation deadline; first movers reach buyers as the low-cost, low-risk option while competitors scramble.
EUDR questions, answered
When does the EUDR apply after the latest delay?
Under Regulation (EU) 2025/2650, published on 23 December 2025, the obligations apply from 30 December 2026 for medium and large operators and traders, and from 30 June 2027 for micro and small operators established by 31 December 2024. The earlier 30 December 2025 and 30 June 2026 dates set by the first postponement are superseded.
What is the EUDR cut-off date?
Covered commodities must come from land that was not subject to deforestation after 31 December 2020, and wood must be harvested without inducing forest degradation after that date. The cut-off was fixed by Regulation (EU) 2023/1115 and has not moved through either postponement.
Is India high risk or low risk under the EUDR?
India is classified a low-risk country under Commission Implementing Regulation (EU) 2025/1093 of 22 May 2025. EU operators sourcing exclusively from low-risk countries may apply the simplified due diligence of Article 13, which sets aside the risk assessment and mitigation steps, while the information and geolocation duties remain in full.
Who files the due diligence statement?
The operator that first places the goods on the EU market or exports them files the statement in the EU information system, which is usually the European buyer. The Indian supplier provides the plot geolocation, deforestation-free evidence and traceability records the statement depends on. Downstream businesses pass on the statement's reference number rather than filing fresh ones.
What geolocation data does the EUDR require?
The geolocation of every plot of land where the commodity was produced, as latitude and longitude with at least six decimal digits. Plots larger than four hectares need polygon coordinates describing the perimeter, with cattle plots exempt from the polygon requirement.
What are the penalties for breaking the EUDR?
Member States must set maximum fines of at least 4 percent of the operator's total annual Union-wide turnover, and can confiscate the products and revenues and exclude a business from public procurement for up to 12 months under Article 25. Non-compliant goods can also simply be refused entry to the market.
Are Indian exporters directly regulated by the EUDR?
No. The legal duties bind the EU operator placing the goods on the market. The practical burden still lands on the exporter, because the geolocation data, the 2020 baseline evidence and the legality records can only come from the production side, and EU buyers choose suppliers who deliver that package reliably.
GreenSutra prepares exporters of coffee, cocoa, rubber, soya, leather and wood products for the 30 December 2026 date with end to end EUDR compliance solutions covering plot geolocation, deforestation-free evidence and the due diligence data package EU buyers file.
