EUDR: Dates, Geolocation Data and What Product Teams Actually Need

Legal status

Regulation (EU) 2023/1115 establishes the core EUDR framework. Regulation (EU) 2026/2102 now amends Annex I.

Keep three dates separate:

• 18 September 2026: the Annex I amendment entered into force
• 30 December 2026: main EUDR application point for the first cohort under the Regulation's timing rules
• 30 December 2027: application date expressly attached to specified additions made by the 2026 Annex amendment, as well as any other role/size timing that must be read from the governing law

Do not turn the amended Annex into one undifferentiated date. The Radar shows which EU product rules apply now and which start later.

The first job is classification

EUDR does not regulate every product containing cattle, cocoa, coffee, oil palm, rubber, soya or wood. It regulates the relevant commodities and relevant products defined through the Regulation and Annex I.

Product teams should start with:

1. the product as placed on the market
2. its CN classification
3. the current Annex I wording, including ex limits and exclusions
4. the business's role and the applicable date

The 2026 amendment deleted the old cattle hide and leather entries and two broad rubber entries, so none of them is a current shortcut: the codes are in What changed in EUDR Annex I?, with worked answers for tyres and rubber and leather and footwear.

What data does EUDR actually require?

For a product that is in scope and for a business performing a role that carries due-diligence obligations, the Regulation requires a due-diligence process built around information collection, risk assessment and risk mitigation where needed.

Product and supply-chain data can include:

• description, quantity and relevant commodity/product information
• country of production
• geolocation of plots of land where relevant commodities were produced
• production date or time range where required
• supplier and customer information
• evidence supporting deforestation-free and legal-production conclusions
• the due-diligence statement and its reference where required

The exact operational set depends on the legal pathway. Do not collect an EUDR evidence pack before establishing scope and role.

Traceability supports the process. It is not the whole due-diligence test.

Knowing where a product came from is necessary, but EUDR is not satisfied by traceability alone. The business must perform the due-diligence steps required by the Regulation and retain defensible evidence for the conclusion reached. Supply-chain mapping, traceability and chain of custody are compared on their own page.

Geolocation is not a generic supplier address

Where plot geolocation is required, a supplier's registered office, factory address or warehouse location is not a substitute. Product teams need the production-location evidence specified by EUDR for the relevant commodity.

So EUDR data collection can cut across ERP, supplier onboarding, geospatial data and compliance evidence rather than living in one product-master field.

What businesses should do now

1. Re-run scope against the amended Annex

Do this first, especially where old rules used cattle leather, broad rubber entries, palm-derived downstream products or wood/furniture shortcuts.

2. Record scope provenance

Keep the CN code, Annex version and date checked with the decision. A result without version provenance is fragile after a material Annex amendment.

3. Separate 2026 products from deferred 2027 additions

Do not force newly added entries with an express 30 December 2027 date into the 2026 operating cohort.

4. Map legal roles

Manufacturer, importer, exporter, operator and trader concepts cannot be guessed from a commercial job title. Map the transaction and the Regulation's definitions.

5. Build evidence around the legal conclusion

For in-scope products, connect supplier data, geolocation, risk assessment, mitigations and due-diligence statement handling. Keep the evidence that explains why the conclusion is defensible.

Non-EU sellers: the role test is different from DPP

Do not import an ESPR/DPP role model into EUDR. A non-EU seller needs the EUDR transaction and role analysis appropriate to the way the product enters or leaves the EU market.

The due-diligence statement is not the evidence itself

A statement or reference number is an output of the due-diligence process. It is not a replacement for the underlying information, risk assessment and mitigation evidence that support the conclusion.

Which EUDR data can be reused elsewhere?

Product identity, supplier identity, material/composition context, country of production and evidence objects may be useful across other product-regulatory workflows. Reuse should preserve provenance and legal meaning rather than relabelling one regime's evidence as another regime's proof. You can check which of your product facts are usable now in your browser.

What this does not mean

• An in-scope material somewhere in a supply chain does not automatically make the finished article a relevant product.
• A deleted Annex entry must not be kept alive because an old questionnaire or rule still contains it.
• A deferred addition is not a 2026 duty merely because it now appears in Annex I.
• A due-diligence statement does not remove the need for the underlying due-diligence process.

What would change this page

This page should change if Annex I is amended again, the EUDR application timetable is legally changed, a Commission act alters an operating requirement, or authoritative guidance materially changes how a core due-diligence step should be implemented.

Primary sources

• Regulation (EU) 2023/1115 on deforestation-free products
• Commission Delegated Regulation (EU) 2026/2102 amending Annex I