EUDR from 30 December 2026: what sellers outside the EU need before customs release

From 30 December 2026, wooden furniture, coffee, chocolate, rubber goods and other products made from seven commodities need a due diligence statement to enter the EU, or from 30 June 2027 for many micro and small companies. The statement is an EU obligation, filed before customs release, and it rests on data only your supply chain has: where each plot is, who supplied the goods, and proof they were produced legally. Here is what is in scope, who files, what customs checks and what you need to supply.

Short answer

The EU Deforestation Regulation (EUDR) covers products made from cattle, cocoa, coffee, oil palm, rubber, soya and wood, as listed in its Annex I. From 30 December 2026, such goods are released into the EU only after a due diligence statement shows they come from land not deforested after 31 December 2020 and were produced legally. The operator files it, which is generally the company the goods are imported for, even when it is outside the EU, and the reference number goes into the import declaration. Micro and small companies established as such by 31 December 2024 have until 30 June 2027, except for wood products already under the EU Timber Regulation.

Last reviewed: November 2026

30 Dec 2026: The EUDR applies to large and medium operators, and to micro and small ones for wood under the EU Timber Regulation; European Commission
30 Jun 2027: For micro and small operators established as such by 31 December 2024, except wood under the EU Timber Regulation; European Commission
31 Dec 2020: Cut-off date: goods from land deforested after it can't be placed on the EU market; European Commission
No minimum: No quantity or value below which the rule stops applying: one parcel is in scope; European Commission

Which goods are in scope

The rule covers the products listed by HS code in Annex I of the Regulation, as updated by Delegated Regulation (EU) 2026/2102. A product not on the list is out, even if it contains one of the seven commodities: margarine made with palm oil, for example.

Commodity	In scope, for example	Not covered, or later
Wood	Wooden furniture and wooden seats, wooden tableware and kitchenware, frames, ornaments and other articles of wood, plywood, sawn wood, pulp, paper and paperboard articles	Bamboo and rattan, printed books, car and aircraft seats, used and second-hand wooden goods, packaging that only carries another product
Coffee	Green, roasted and decaffeinated coffee, coffee husks and skins	Soluble (instant) coffee: in scope from 30 December 2027
Cocoa	Cocoa beans, paste, butter and unsweetened powder; chocolate and other food preparations containing cocoa	Palm oil inside a chocolate bar: due diligence covers only the cocoa
Rubber	Natural rubber, new tyres and inner tubes, gloves and other apparel of vulcanised rubber, rubber plates and sheets, hard rubber	Removed in 2026: other articles of vulcanised rubber (heading 4016), conveyor belts, retreaded tyres except new treads. Synthetic rubber is not covered
Oil palm	Palm oil and palm kernel oil, palm nuts and kernels, and palm-based glycerol, stearic acid and industrial fatty alcohols	More palm derivatives, including soap made with palm oil, from 30 December 2027
Soya	Soya beans, soya flour and meal, soya oil and oilcake	Soya beans for sowing, removed in 2026
Cattle	Live cattle, beef (fresh, chilled or frozen), edible offal, prepared or preserved beef	Hides, skins and leather, removed in 2026. Frozen cattle tongues from 30 December 2027. Buffalo and bison are not covered

Your HS code decides. Check it against Annex I, linked from the European Commission's EUDR page. Samples of negligible value and quantity, used only to seek orders, are outside the Regulation.

Who files the statement when you sell from outside the EU

The EUDR makes the operator answer for the goods. The operator is generally the company named as importer when the goods are released for free circulation, wherever it is established.

You are the operator

When your goods are imported for you, you exercise due diligence and the statement is in your name. To use the EU Information System you need an EORI number issued in the EU.

Your customs representative is not

A customs representative lodges the declaration but never becomes the operator. The statement can be submitted for you by an authorised representative established in the EU, under a separate written mandate: we do this for our clients. You stay responsible either way.

Your EU business buyer is one too

When you sell to an EU company, the first one that makes the goods available in the EU is also an operator and files its own statement. When you sell to consumers, the consumer is never the operator.

From your supplier to customs release

1

Collect the data

Geolocation of every plot, supplier and buyer details, quantities and evidence of legal production, from your supply chain.
2

Assess the risk

Check the data against the Regulation's risk criteria and reduce any risk that is more than negligible. Simplified when everything comes from low-risk countries.
3

File the statement

In the EU Information System, part of the TRACES platform, before the import declaration. The system returns a reference number.
4

Declare the goods

The declarant puts the reference number in the import declaration. One statement can cover several shipments for up to a year, and one declaration can carry several numbers.
5

Release

Without the number, the goods are not released for free circulation. If the competent authority flags them as high risk, release is suspended for up to 3 business days, or 72 hours for perishable goods, longer if checks need it.

After release, pass the reference number to your EU business buyers and keep the due diligence records for 5 years.

Low, standard or high risk: the country benchmarking

The European Commission classes every country as low, standard or high risk of producing the seven commodities on deforested land. The list was adopted in 2025 by Implementing Regulation (EU) 2025/1093.

Risk	Countries, for example	What it means for due diligence
Low	India, China, Viet Nam, Türkiye, Thailand, the Philippines, Ghana, the United States	Simplified due diligence: you still collect all the information, including geolocation, and check that nothing from other sources is mixed in, but no full risk assessment or mitigation. Fewer checks by the authorities
Standard	Brazil, Indonesia, Malaysia, Colombia, Côte d'Ivoire, Peru, Mexico, Cameroon	Full due diligence: information, risk assessment and, where needed, risk mitigation
High	Belarus, Myanmar, North Korea, Russia	Full due diligence, and the closest scrutiny by the authorities

Simplified due diligence applies only when all of the commodity comes from low-risk countries. A micro or small producer in a low-risk country that places its own harvest on the EU market itself can file a one-time simplified declaration, with a postal address instead of geolocation. Find your country in the Commission's list.

What you need to supply

Producers outside the EU have no obligations of their own unless they place goods on the EU market themselves, but the operator can't file without their data. If the data can't be obtained, the goods can't be placed on the EU market.

Geolocation of every plot

Latitude and longitude with at least six decimal digits
A polygon for plots over 4 hectares, a single point for smaller ones
For cattle, every establishment where the animals were kept
The date or time range of production
For furniture made of several woods, every plot behind every component

Supplier and product data

Description, trade name and HS code; for wood, the common and scientific name of the species
Quantity in kilograms of net mass
Country of production
Name, postal address and e-mail of your supplier and of your buyer

Evidence of legal production

Land use rights and environmental protection
Forest rules, where wood is harvested
Third parties' rights, labour rights and human rights
Free, prior and informed consent of indigenous peoples
Tax, anti-corruption, trade and customs rules

The law of the country of production applies. A sustainability certificate can support the risk assessment, but it doesn't replace due diligence. Noda is not a certification body and doesn't map plots: your supplier and a specialist partner provide the data.

Parcels or bulk: what changes

1. Parcels to EU consumers

Every parcel is in scope, at any value. You are the operator: you file a statement for the quantity you plan to sell, and its reference number goes into each parcel's customs declaration. One statement can cover your shipments for up to a year.

You need an EU EORI number to use the Information System. Parcel duty and fees: EU parcel rules 2026.

2. Bulk to stock in the EU

One shipment, one import declaration with the statement's reference number. Orders then go to EU consumers from stock, with no new statement per order. An EU business that buys from your stock is an operator too and files its own statement.

We act as your importer and VAT representative, provide the warehouse and 3PL, and submit the statement for you, with a specialist partner checking the data.

3. Your EU buyer imports

Your EU distributor or retailer imports the goods, becomes the operator and files the statement. It will ask you for the same geolocation, supplier and legality data before it orders.

Not sure which route is yours? Check your EU roles.

Compare the cost per order: Selling into the EU from abroad → · EU parcel rules 2026 →

An EU obligation, next to your other EU roles

The statement sits beside the importer, VAT and warehouse your goods need anyway. Who does each part, and where we fit.

Task	Who does it	With Noda
Geolocation, supplier and legality data	Your supplier and the producer; the operator answers for it	Your supplier and a specialist partner provide it. We don't map plots or certify products
Due diligence statement	The operator, or an authorised representative established in the EU	A specialist partner checks the data with you; we submit the statement for you in the EU Information System as your authorised representative, under a separate written mandate, before your goods are released. The price is in your proposal
Import declaration with the reference number	A declarant established in the EU: the importer or its indirect customs representative	We act as your importer in Estonia, as indirect customs representative, from €200 to set up and from €50 per shipment
EORI number	Every importer, and every operator from outside the EU that uses the Information System	We file the application when your first customs operation is in Estonia
VAT	A VAT registration where the stock is; companies from outside the EU register through a representative	We act as your VAT representative in Estonia, from €99 a month
Storage and orders	Goods held in the EU and sent to customers	Warehouse and 3PL across Estonia, the Baltics and Europe. Goods in scope come into stock only with the reference number of their statement, kept with the stock records for 5 years. The stock stays yours

Dates to plan around

Date	What happens
31 Dec 2020	Cut-off date: goods from land deforested after it, or from wood harvested in a way that degraded forest after it, can't be placed on the EU market
29 Jun 2023	The EUDR enters into force
19 Dec 2025	Regulation (EU) 2025/2650 postpones the dates by a year and leaves the statement to the operator who first places the goods on the market
Jun 2026	The EUDR Information System reopens
13 Jul 2026	The European Commission adopts the update of the product list
18 Sep 2026	Delegated Regulation (EU) 2026/2102 enters into force: leather and several rubber products leave the list
30 Dec 2026	The EUDR applies to large and medium operators, to all downstream operators and traders, and to micro and small operators for wood products under the EU Timber Regulation. The EU Timber Regulation is repealed
30 Jun 2027	The EUDR applies to micro and small operators established as such by 31 December 2024
30 Dec 2027	Added products come into scope: soluble coffee, palm-oil derivatives including soap, frozen cattle tongues

Common questions

When does the EUDR apply to my goods?

From 30 December 2026 for large and medium operators, and for all downstream operators and traders. Micro and small operators established as such by 31 December 2024 have until 30 June 2027, except for wood products already under the EU Timber Regulation, which follow the December 2026 date. Company size is measured by the thresholds of the EU Accounting Directive. Products added in 2026, such as soluble coffee, soap made with palm oil and frozen cattle tongues, come into scope on 30 December 2027.

Who files the due diligence statement when I sell from outside the EU?

The operator: generally the company named as importer when the goods are released for free circulation. When the goods are imported for you, that is you, even though you are outside the EU, and you need an EORI number issued in the EU to use the Information System. An authorised representative established in the EU can submit the statement for you under a written mandate, but the responsibility stays with you. When you sell to an EU business, that buyer is an operator too and files its own statement.

Is my customs representative the operator?

No. A customs representative lodges the declaration, but it neither places the goods on the market nor exports them, so it is never the operator. When we declare your goods as indirect customs representative, you remain the operator. Submitting the statement on your behalf is a separate role, with a separate written mandate: we take it as your authorised representative, and you remain responsible as the operator.

Will customs release my goods without the statement?

No. The reference number of the due diligence statement must be made available to customs before release, in the import declaration. So the statement is filed, and the number received, before the declaration is lodged. If the competent authority flags the goods as high risk, release can be suspended for up to 3 business days, or 72 hours for perishable goods, and extended if the checks need more time. Goods found non-compliant are not released.

Is leather still covered by the EUDR?

No. Delegated Regulation (EU) 2026/2102 removed cattle hides, skins and leather from the list, from 18 September 2026. Live cattle, beef and edible offal stay in scope, and frozen cattle tongues come in on 30 December 2027.

Do parcels to EU consumers need a statement?

Yes. The rule has no minimum quantity or value, and it covers online and distance sales. The consumer is never the operator, even when named as importer on the customs declaration: the seller that actually supplies the goods is. Each parcel's declaration carries a reference number, and one statement can cover several shipments for up to a year. Only parcels between private persons, such as gifts between relatives, are outside the rule.

My goods come from a low-risk country. Do I still need geolocation?

Yes. There is no exception for geolocation. Low risk means simplified due diligence: you collect all the information and check that nothing from standard-risk, high-risk or unknown sources is mixed in, but you don't need a full risk assessment or mitigation. India, China, Viet Nam, Türkiye and Thailand are low risk; Brazil, Indonesia, Malaysia and Côte d'Ivoire are standard risk.

What about stock I import before 30 December 2026?

Goods placed on the EU market before the date that applies to the operator need no due diligence statement, and the customs declaration is the evidence of that date. Later sales of that stock in the EU don't need one either; keep the evidence. Wood products under the EU Timber Regulation have their own transitional rules.

Can a sustainability certificate replace the statement?

No. Certification schemes can help the risk assessment where they cover the information the Regulation asks for, but the operator still exercises due diligence, files the statement and stays responsible.

Does Noda map plots or certify products?

No. We are not a certification body and we don't map plots of land. Your supplier and a specialist partner provide the geolocation and supply chain data. We submit the due diligence statement for you in the EU Information System, under a separate mandate, before your goods are released, and we can declare the goods as your importer. The price is in your proposal.

What happens if the goods don't comply?

They may not be placed on the EU market, and customs does not release goods the competent authority finds non-compliant. Each EU country sets the penalties. They include fines with a maximum of at least 4% of the company's annual EU turnover, and confiscation of the goods and of the revenue from them.

Sources: Regulation (EU) 2023/1115 (EUDR), as amended by Regulation (EU) 2024/3234, Regulation (EU) 2025/2650 and Delegated Regulation (EU) 2026/2102, consolidated text of 18 September 2026; European Commission, DG Environment, EUDR page, product scope update of 13 July 2026, Guidance document C/2026/3896 and Frequently Asked Questions, version 5; European Commission, Green Forum, roles and responsibilities, due diligence and country classification list; Commission Implementing Regulation (EU) 2025/1093 (country benchmarking); European Commission, Access2Markets, EUDR delay to December 2026; European Commission, DG TAXUD, prohibitions and restrictions. Last reviewed: November 2026.

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