What EUDR does on 30 December, in one diagram

From 30 December 2026, a consignment of coffee, cocoa, soy, palm oil, rubber, beef or wood cannot be sold in the European Union, or exported from it, unless the company that first puts it on the market has filed a statement in a Commission database identifying the plots of land it came from and confirming that none of them was deforested after 31 December 2020. The rule is Regulation (EU) 2023/1115, the EU Deforestation Regulation, in force since June 2023 and postponed twice. Large and medium companies are covered from 30 December; micro and small ones from 30 June 2027.

The regulation applies to seven commodities, cattle, cocoa, coffee, oil palm, rubber, soya and wood, and to the goods made from them that are listed in its annex: chocolate, tyres, furniture, pulp and paper, palm-oil derivatives and the rest. Three conditions must all be met before any of them can be sold or exported: the product is deforestation-free, it was produced under the laws of the country where it was grown, and it is covered by a due diligence statement or, for the smallest producers, a simplified declaration. The world lost about 10 million hectares of forest a year to deforestation between 2015 and 2020, by the FAO's count; the regulation is the EU's attempt to close its own market to the part of that loss it pays for.

The mechanism

How it got here

The regulation is the end of an eighteen-year line that runs from a communication to a database. The dates below are from the EU's own records, with the votes as counted.

What changed in December 2025

The regulation was due to apply from 30 December 2024. A first postponement moved it to 30 December 2025. In December 2025 the Parliament, by 405 votes to 242 with 8 abstentions, and the Council agreed a second delay and a set of simplifications, published as Regulation (EU) 2025/2650. The application dates became 30 December 2026 for large and medium companies and 30 June 2027 for micro and small ones. The duty to file a due diligence statement was confined to the company that first places a product on the market or exports it; everyone downstream keeps and passes on reference numbers instead. Micro and small primary producers file a single simplified declaration. Printed products, books and newspapers among them, left the scope. The Commission was told to review the regulation for further simplification and report by 30 April 2026, with a legislative proposal if it saw the need.

It reported in May. The package of 4 May 2026 contained the review, a third edition of the guidance and a fifth of the questions and answers, and a draft delegated act adjusting the product list. The Commission said it would not reopen the text of the regulation, and put the annual compliance cost of the simplified design at 75% below the original. On 13 July it adopted the delegated regulation with targeted fixes to the annex, which Parliament and Council have two months to object to, and an implementing regulation on the Information System that has been in force since 17 July. The date, in other words, has stopped moving.

The country tiers

Where a plot sits decides how much work the statement takes and how likely the check is. The Commission published its first country list on 22 May 2025: 4 countries high risk, Belarus, Myanmar, North Korea and Russia; 50 standard, including Brazil and Indonesia; 140 low, including every EU member state, the United States, China and Australia. Sourcing from a low-risk country still requires geolocation and a statement, but not the risk assessment and mitigation that standard and high-risk origins require. The Parliament objected to the list on 9 July 2025, by 373 votes to 289, on the grounds of method and data, and asked the Commission to withdraw and revise it. The resolution is not binding and the list stands.

Who is exposed

The obligation falls on the first placer, which for most of the seven commodities is a trader or a manufacturer with an EU entity: a coffee roaster, a chocolate maker, a tyre company, a furniture or paper group, a food company buying palm oil. The risk, however, is created upstream. A trader that cannot produce coordinates for the plots behind a consignment cannot file a statement, and a consignment without a statement cannot enter. From 30 December, traceability becomes a condition of revenue, and the share of a supplier base that can be geolocated becomes a number a buyer's finance function will want to know.

For Africa the exposure is concentrated. Cocoa from Côte d'Ivoire and Ghana, coffee from Ethiopia and Uganda, rubber from Côte d'Ivoire and timber from the Congo basin all enter the EU through the same door. The Commission's own research service has modelled cocoa: the EU buys 68% of its cocoa from Côte d'Ivoire and Ghana and almost 90% from Africa; in 2023 about 51% of the world's beans could be traced to the farm; and under full compliance farmgate prices rise by around 15%, with the market splitting into compliant and non-compliant beans. In Côte d'Ivoire, 61% of cocoa exports went to the EU and Switzerland in 2022, and only about 35% of exports were sourced directly from cooperatives, the channel through which a plot can be traced. For the Johannesburg market, the direct exposure is in wood products, since pulp and paper are in the annex, which touches Sappi and Mondi, and in the agricultural traders that sell into the EU.

What the research says

The studies below are the ones a reader is most likely to need, each with the figure it is known for.

The case for the law. The Commission's impact assessment (November 2021) counted at least 71,920 hectares a year of deforestation avoided and 31.9 million tonnes of carbon a year by 2030, worth at least EUR 3.2bn a year, and put EU consumption at 10% of world deforestation between 1990 and 2008. WWF's Stepping up? (April 2021), built on Trase data, made the EU the second-largest importer of tropical deforestation after China: 16% of the deforestation linked to international trade in 2017, 203,000 hectares and 116 million tonnes of CO2, with soy, palm oil and beef the largest items and eight member states accounting for 80% of the total. The attribution method behind both is Pendrill and others in Global Environmental Change (2019). The Joint Research Centre's cocoa study (July 2025) is the most detailed forecast of what the law does to a single commodity: cocoa-related deforestation down about 34,000 hectares a year, or 23%, under a ban, with part of the gain lost to leakage into other markets.

The costs and who bears them. The Commission's own estimates have moved twice: a 30% cut in administrative costs from the April 2025 simplifications, then a design costing 75% less than the original after the May 2026 review. The JRC assumes traceability at US$75 a tonne of cocoa. Zhunusova and others, in Forest Policy and Economics (2022), was the first peer-reviewed assessment of what the proposal would do to smallholders, Indigenous peoples and local communities, and named the risk that the law now turns on: exclusion where land titles, geodata and organisation are missing. SEI Asia (September 2024) put the scale for Southeast Asia at about 100 million smallholders, who grow 40% of the world's palm oil and of whom 10% hold RSPO certification. On the finance side, Global Canopy's Forest 500 (June 2026) found that 59% of the 150 financial institutions it assessed have no deforestation policy for the seven commodities.

Smallholders in their own words. The Forest and Farm Facility survey run by IIED (October 2025) asked 286 producers in Latin America, Africa and Asia between April and May 2025: 48% had not heard of the regulation; 44% had their land mapped; 30% of those growing a covered commodity had no smartphone; over 48% held no land title; 45% had received no support of any kind; and 22% feared losing their market. Trase (August 2024) set out the Ivorian cocoa numbers above and argued for a national traceability system rather than one built by each buyer.

For an investor, the regulation turns two of the things the desk scores, transparency about where a company's inputs come from and the response it has made, into a licence to sell in the world's largest single market. A company that can show its plots has a supply chain; one that cannot has, from 30 December, a supply chain that stops at the EU border.