EUDR Compliance Guide

EUDR solutions prepare a business for the EU Deforestation Regulation, Regulation (EU) 2023/1115, which will require covered commodities to be deforestation-free and legally produced before they reach the European market. The work covers mapping products against the seven covered commodities, geolocating every production plot, assembling evidence that the land was not deforested after 31 December 2020, and readying the trail so the European operator can file the due diligence statement in the EU information system. The aim is an export supply chain that is ready before the obligations apply.

Under Regulation (EU) 2025/2650, published on 23 December 2025, the obligations will apply from 30 December 2026 for medium and large operators and traders, and from 30 June 2027 for micro and small operators and traders established by 31 December 2024. The earlier 30 December 2025 and 30 June 2026 dates set by Regulation (EU) 2024/3234 are superseded, and the original 30 December 2024 date never took effect. The regulation is not yet applying, so the period now is a preparation window.

The regulation covers seven relevant commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood, together with the products derived from them listed in Annex I, such as leather, chocolate, furniture, soya meal and palm oil derivatives. Printed products of Chapter 49 of the Combined Nomenclature, such as books and newspapers, were removed from Annex I by Regulation (EU) 2025/2650 and are no longer in scope.

India is classified a low-risk country under Commission Implementing Regulation (EU) 2025/1093 of 22 May 2025. An operator sourcing exclusively from a low-risk country may apply the simplified due diligence of Article 13, which sets aside the risk assessment and risk mitigation steps unless the operator becomes aware of information pointing to a risk of non-compliance. Only four countries are classified high risk, and India is not among them, so the low-risk benchmark is a genuine advantage for Indian exporters.

Due diligence requires the geolocation of every plot of land where the commodity was produced, given as latitude and longitude using at least six decimal digits. For plots of more than four hectares used to produce relevant commodities other than cattle, the geolocation must be provided as polygons describing the plot perimeter. Cattle plots are exempt from the polygon requirement, which is a point the data capture has to get right.

The due diligence statement is filed in the EU information system by the operator that first places the goods on the market or exports them, which is usually the European-side operator. An Indian supplier provides the plot geolocation, the deforestation-free evidence and the traceability records that the operator needs. Where the exporter places the goods on the market through its own European entity, that entity is the operator and files the statement itself.

A commodity must be produced on 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 is a fixed baseline and was not changed by the 2025 amendment, so plots that were forest after that date and cleared since cannot supply covered commodities to the European market once the obligations apply.

No. As amended by Regulation (EU) 2025/2650, the full due diligence statement obligation falls on the operator carrying out the first placing on the market or export. A downstream operator registers in the information system and passes on the reference number issued for that statement rather than filing a fresh one. A micro or small primary operator uses a one-time simplified declaration and receives a declaration identifier sufficient for traceability.

Under Article 25 the maximum fine must be set at least at 4 percent of the operator or trader total annual Union-wide turnover in the year before the fining decision, and each EU Member State sets the actual level and may go higher. Penalties also include confiscation of the relevant products and of the revenues gained, temporary exclusion of up to 12 months from public procurement and public funding, and, for serious or repeated infringements, a temporary ban on placing the products on the market or exporting them.

No. India being low risk lets the European operator apply the simplified due diligence of Article 13, which sets aside the risk assessment and risk mitigation steps, but the information and geolocation duties remain in every case. Plot coordinates, polygons for plots over four hectares other than cattle, and evidence that the land was not deforested after 31 December 2020 are still required, and the simplification falls away if the operator becomes aware of a non-compliance risk.

Member State authorities must check at least 9 percent of operators placing products from high-risk countries, 3 percent for standard-risk countries and 1 percent for low-risk countries, counted per commodity under Article 16. Sourcing from India therefore sits in the lightest inspection tier, provided the geolocation and evidence package behind each due diligence statement holds up when a check does come.

No. The EU Deforestation Regulation is one of several European frameworks an Indian exporter may face, separate from the Carbon Border Adjustment Mechanism and other EU rules. A business serving the European market may carry more than one obligation at once, and meeting the EUDR satisfies only the deforestation due diligence requirement. Where several frameworks apply, planning them together keeps each obligation from being missed.

Due diligence statements are submitted electronically, before products are placed on the EU market, through the EUDR Information System established under Article 33. This is the register of due diligence statements built on the European Commission TRACES platform. Each submitted statement generates a reference number, together with a verification number that operators and traders pass along the supply chain so that downstream actors and competent authorities can confirm a statement exists. The reference and verification numbers confirm that a statement has been filed; they do not expose the full underlying supply-chain data to a recipient.

Under Regulation (EU) 2025/2650, only the first operator placing a product on the EU market files a full due diligence statement, while downstream operators and traders may rely on and pass on the existing reference number, and micro or small primary operators may submit a one-time simplified declaration. The further simplifications announced in the European Commission May 2026 package, including voluntary grouping or bulk submission and updated submission mechanics, are delivered through draft implementing and delegated acts and guidance that, as of mid-2026, are not all formally adopted. The first-operator and one-time-declaration changes are binding now; the grouping and bulk-submission mechanics are announced and pending rather than settled law.

The EU Deforestation Regulation attaches its obligations to the relevant commodities and the products derived from them as listed in Annex I, and Annex I identifies those products by their Combined Nomenclature codes, the EU classification built on the international Harmonised System. Confirming the correct CN code for each exported product is therefore how a business establishes whether a good falls inside Annex I and so inside the regulation. The same classification basis is why printed products of Chapter 49, such as books and newspapers, could be removed from Annex I by Regulation (EU) 2025/2650, and it is the first check in scoping a supply chain.

Where many smallholder plots feed a single export, a cooperative or aggregator typically gathers the plot geolocation on the growers behalf, recording each plot by latitude and longitude to at least six decimal digits, with a polygon for any plot larger than four hectares used for commodities other than cattle, so the consolidated package can support the due diligence statement. Sourcing exclusively from low-risk India lets the operator apply the simplified due diligence of Article 13, yet the information and geolocation duties remain in every case, so the aggregator collecting accurate per-plot coordinates is what lets the European operator file once and pass the reference number down the chain.

No. Voluntary certification or third-party verified schemes such as RSPO, Rainforest Alliance, FSC or PEFC can be used as one source of information in the EUDR risk assessment, but they do not replace the operator own due diligence or the obligation to submit a due diligence statement, and the operator retains full legal responsibility for compliance. There is no EUDR certification that exempts a business from due diligence, so plot-level geolocation and deforestation-free evidence are still required whatever certificates a supply chain already holds.

Operators and traders must keep their due diligence statements and the supporting documentation and information for five years from the date the relevant products were placed on, made available on, or exported from the EU market, and must make them available to competent authorities on request. The five-year clock runs from when the products entered the market rather than from the date the statement was filed, so the geolocation, evidence and traceability package behind each consignment is retained for five years after that consignment moved.

No. The India and European Union free trade agreement does not provide any exemption from the EU Deforestation Regulation. The regulation remains fully applicable to imports from India once the obligations apply, and the low-risk benchmarking under Implementing Regulation (EU) 2025/1093 is what lets an operator sourcing exclusively from India apply the simplified due diligence of Article 13, rather than any trade-agreement carve out. Indian exporters of covered commodities to the European market stay subject to the mechanism, which is why an EUDR consultant in India works from the regulation as it stands.