EUDR: Dates, Geolocation Data and What Product Teams Actually Need
Prepare for EUDR application with the right product scope, CN classification, plot geolocation, supplier evidence and due-diligence records.
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The EU Deforestation Regulation is now a near-term product-data obligation, not just a sustainability policy. Under the current consolidated Regulation (EU) 2023/1115, the main obligations apply from 30 December 2026. A later date, 30 June 2027, applies to qualifying natural persons and micro or small undertakings established as such by 31 December 2024, subject to the regulation's timber-transition exception. The scope test is product-specific: the item must fall within Annex I and be associated with cattle, cocoa, coffee, oil palm, rubber, soya or wood. For an in-scope product, due diligence needs product/quantity information, country of production, supplier and customer records, geolocation of the relevant plots or cattle establishments, evidence of legality and deforestation-free production and a due diligence statement before placing, making available or exporting where required.
Legal status
| Question | Current answer |
|---|---|
| Instrument | Regulation (EU) 2023/1115 - EUDR, current consolidated text |
| Status | ADOPTED - APPLIES LATER |
| Main application | 30 December 2026 |
| Qualifying micro/small operators | 30 June 2027, subject to the regulation's transition rule for products formerly covered by the EU Timber Regulation |
| Product scope | Annex I products linked to cattle, cocoa, coffee, oil palm, rubber, soya and wood |
| 2026 scope development | Commission adopted C(2026) 4920 on 13 July 2026 to amend Annex I; the drafting-day EUR-Lex record still shows the act without a final EU act number |
Primary law: Regulation (EU) 2023/1115. Commission-adopted Annex I amendment: C(2026) 4920 final4920).
The first job is classification
EUDR is not triggered merely because a product contains wood, rubber, leather, cocoa or palm-derived material.
The legal scope is defined through Annex I and Combined Nomenclature codes. A product team therefore needs a three-part test:
- What is the product's correct CN/HS classification?
- Is that code or description in the current Annex I?
- Which relevant commodity is connected to it?
Do not replace that test with keyword matching against a bill of materials.
The scope is also moving. On 13 July 2026 the Commission adopted delegated act C(2026) 4920 to make targeted changes to Annex I. As at the verification date for this page, EUR-Lex still presents it as a Commission-adopted delegated regulation without a final act number. Treat it as an officially adopted Commission measure in the delegated-act process, but do not silently overwrite the current consolidated Annex I until publication, scrutiny and entry-into-force status are confirmed.
What data does EUDR actually require?
Article 9's information layer is the heart of the product-data job. For relevant products and commodities it includes information such as:
- description, including trade name and product type;
- quantity;
- country of production;
- geolocation of all plots of land where the relevant commodities were produced, or the establishments for cattle;
- production date or time range where required;
- supplier information;
- customer/business-recipient information where applicable;
- adequately conclusive and verifiable information that the products are deforestation-free;
- adequately conclusive and verifiable information that production complied with relevant legislation in the country of production.
Operators then use that information for risk assessment and, where necessary, risk mitigation before submitting the required due diligence statement.
This is not normal catalogue data. Geolocation and production evidence often sit outside the retailer's existing PIM, which is why the owner of the fact matters. See Which System Should Own Each Product Fact?.
What businesses should do
| Action | What it means in practice |
|---|---|
| DO NOW | Classify products against the current Annex I using actual CN codes and product descriptions. |
| DO NOW | Map whether your legal entity is an operator, downstream operator or trader under the current EUDR rules rather than importing a role definition from another regime. |
| DO NOW | Request plot-level geolocation and production/supplier evidence for in-scope supply chains while there is still time to resolve gaps. |
| DO NOW | Connect EUDR evidence to the exact product/batch/consignment and supplier it supports. |
| PREPARE | Build due-diligence-statement references and five-year retention into the governed record and operational workflow. |
| WATCH | Publication/entry into force of C(2026) 4920 and any further Commission implementation changes. |
| DO NOT HARD-CODE | The Commission-adopted July 2026 Annex I amendment as if it were already the current consolidated Annex until its legal lifecycle is confirmed. |
Non-EU sellers: the role test is different from DPP
EUDR has its own definitions and deeming rules.
Where a person established outside the Union places a relevant product on the market, the first person established in the Union who makes that relevant product available on the market can be treated as the operator for EUDR purposes under the regulation's third-country rule.
That is why the existing Who Carries the Digital Product Passport Obligation? page should link here but should not be expanded into an EUDR role guide. The DPP role test and the EUDR role test answer different legal questions.
The due diligence statement is not the evidence itself
A reference number or successful submission does not make the underlying product facts true.
The due diligence statement is the formal output of a process. The evidence behind it still needs provenance and version control. A plot coordinate can be syntactically valid and belong to the wrong supplier. A country-of-production field can be complete and still be inconsistent with customs documentation. A supplier declaration can exist and still fail to support the exact batch.
The useful architecture therefore separates:
fact → what is asserted;
evidence → what supports it;
risk decision → what assessment was made;
submission → what was sent to the EUDR Information System and when.
That maps naturally into the existing Evidence & Trust model.
What this does not mean
It does not mean every product containing a relevant commodity is in scope. Annex I classification decides the relevant products.
It does not mean a Digital Product Passport can replace an EUDR due diligence statement. The regimes can reuse governed facts, but their legal outputs are distinct.
It does not mean the June 2027 date applies to every SME. The delayed date depends on the specific establishment and transition conditions in Article 38.
It does not mean a July 2026 Commission-adopted delegated act is automatically the current Annex I. Track its delegated-act lifecycle.
What would change this page
Recheck when:
- C(2026) 4920 receives its final publication/entry-into-force status or is objected to;
- Annex I is amended again;
- application dates change;
- Commission Information System or due-diligence implementation rules materially change;
- official guidance changes the scope or role interpretation.
Track the near-term status on the EU Product Regulation Action Radar.
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