Who is affected by the EUDR in 2026?

The EU Deforestation Regulation (EUDR) marks a decisive turning point for global supply chains. From the end of 2026, only products that demonstrably did not contribute to deforestation or forest degradation may be sold in the EU. Companies of every size are affected, from small traders to international groups, as long as they place certain commodities or derived products on the EU market, make them available, or export them. Company size influences deadlines and documentation duties, but small and medium-sized enterprises are not exempt from the EUDR either.

Covered commodities and products

At the heart of the regulation are seven deforestation-relevant commodities regarded worldwide as the main drivers of forest destruction: beef, palm oil, soy, cocoa, coffee, rubber and wood.

It is not only the raw commodities that are covered, but also numerous derived products. Palm oil appears in a wide range of consumer goods, from food to cosmetics to cleaning products. Soy is widely used in animal feed but is also an ingredient in many processed foods. Cocoa is found in chocolate, drinks and baked goods, while coffee is covered in both roasted and instant form. Rubber is used above all for tyres and other rubber products, and wood goes into furniture, paper, pulp, packaging and building materials.

For all these commodities and derived products, companies must prove that they were not produced on land deforested after December 31, 2020. Which products are specifically in scope can be identified precisely via their HS codes.

Position in the supply chain

To derive your specific obligations, the first step is to determine your own role in the supply chain: first operator placing goods on the market, or downstream market participant.

While first operators remain fully obliged to carry out due diligence, including information gathering, risk analysis and submission of a statement, directly downstream market participants face reduced administrative requirements. They no longer need their own risk analysis; instead they must document the reference numbers of upstream statements and ensure complete traceability. Actors further downstream benefit from additional simplifications; their duties are essentially limited to storing basic supplier information and cooperating with the competent authorities.

Due diligence and evidence obligations

The requirements for first operators are extensive. As part of a due diligence procedure, companies must ensure their products are genuinely deforestation-free. This starts with determining and documenting the exact geographic coordinates of the plots of production. This geodata serves as evidence that the goods do not originate from deforested land.

Companies are also obliged to carry out a thorough risk assessment of their supply chains. This is not only about whether a deforestation risk exists, but also whether the legal requirements in the country of origin are met. If a risk is identified, the company must take suitable mitigation measures, such as additional documentation, on-site checks, or switching to more sustainable suppliers.

Finally, all relevant information must be submitted to the authorities via the EU's central TRACES system. In return, companies receive a reference number, without which the goods cannot be imported into the EU. Companies that fail to meet these requirements may no longer bring their goods into the EU single market.

Implementation deadlines

Application is staggered: for large and medium-sized companies the EUDR applies from December 30, 2026; micro and small enterprises have until June 30, 2027. Given the complexity of the requirements, it is strongly advisable to start implementation now: collecting geodata, analysing global supply chains and switching to deforestation-free sourcing all take time and resources.

Support with implementation

Polygon One supports you with end-to-end implementation of the EU Deforestation Regulation, efficiently, with legal certainty, and with a focus on practice. We guide you from precise geolocation of the plots of production through full risk analysis to the integration of your evidence into the EU's TRACES system.

Get compliant. Stay ahead.