EUDR for US exporters: what your European customers will need from you from 30 December 2026

In brief

From 30 December 2026, a European company may release wood, paper, soy, beef, coffee, cocoa, rubber or palm-oil products for free circulation only if it has filed a due diligence statement in the EU information system beforehand. The statement rests on data that sits with you and your suppliers: the plots where the commodity was grown or harvested, the production period, the names of the businesses in the chain and evidence that the land was not deforested after 31 December 2020.

The United States is classified as a low-risk country, which spares your EU customer the formal risk assessment but not the data. Every plot still has to be located, every shipment still has to be traceable to a statement, and products you make from imported commodities pull the plots of your own suppliers into the file. This article sets out what the EU buyer has to do, what will be asked of you, which of your exports are covered and by when.

Why a US company is affected by an EU regulation

Regulation (EU) 2023/1115, the EU Deforestation Regulation or EUDR, binds the operator: the business that first places a relevant product on the Union market or exports it from there. A company established outside the Union cannot normally hold that role. Article 7 provides that where a person established outside the Union places relevant products on the market, the first person established in the Union who makes them available is deemed to be the operator. In practice that is your EU customer, the importer that releases your goods into free circulation.

The obligations therefore fall on the importer, and the importer passes them to you by contract, questionnaire and purchase conditions. The pressure behind those requests is real. Article 25 obliges the member states to set fines of at least four per cent of the operator's total annual Union-wide turnover for the most serious breaches, and a shipment without a valid statement is not released at the border. An importer that cannot get the data from a supplier has two options: source elsewhere or stop importing the product. Neither is good for you.

A second route exists for companies with their own presence in Europe. A US group with an EU subsidiary that imports the goods makes that subsidiary the operator, with the full set of obligations. Under Article 6 an operator may also appoint an authorised representative established in the Union to submit statements on its behalf; the legal responsibility stays with the operator. For most US exporters neither route applies, and the practical answer is the same: your customer files, you deliver the data.

Which US exports are covered

Annex I of the regulation lists the products by Combined Nomenclature code. Only listed codes count; a product made from wood or soy that sits under an unlisted code is out of scope. Where a code carries the prefix "ex", only the part of the heading that contains the commodity is covered. Since 18 September 2026 the list reads as amended by Delegated Regulation (EU) 2026/2102, which removed cattle hides and leather, conveyor belts and vehicle seats and added instant coffee, palm-oil-based soaps and a set of oleochemicals from 30 December 2027. The complete list with every change is in EUDR Annex I and CN codes, and the Excel scope checker matches your codes against it offline.

Two thresholds matter for the calendar. Products produced before 29 June 2023 are outside the regulation altogether, and goods that were placed on the EU market between that date and the start of application count as transitional goods. Both cases have their own customs codes, Y132 and C718, so that your customer can prove them at the border.

What your EU customer has to do

Before the goods are released for free circulation, the operator must exercise due diligence under Articles 8 to 11 and submit a due diligence statement in the EU information system. Due diligence has three parts: collecting the information listed in Article 9, assessing the risk under Article 10 and, where the risk is not negligible, mitigating it under Article 11. The statement carries a reference number that goes into the customs declaration with document code C716; without it the goods stay at the border.

For commodities produced in the United States the second and third parts fall away. Implementing Regulation (EU) 2025/1093 lists the United States among the low-risk countries, and Article 13 allows simplified due diligence for products from low-risk countries: the operator collects the Article 9 information but is not required to assess or mitigate the risk, unless it obtains information pointing to a risk of circumvention or mixing with products of unknown origin. The data collection stays complete. Simplified due diligence is a lighter file, not a lighter data request.

The classification refers to the country where the commodity was produced, not where you are established. Chocolate made in Pennsylvania from Ghanaian cocoa is assessed on the basis of Ghana, tyres made in Ohio on the basis of the rubber's origin in Thailand or Indonesia. That is where most of the work for US processors comes from.

What you will be asked to supply

Article 9 lists the information the operator must hold. Translated into the request you will receive from your customer:

1. Product description with trade name, product type, the relevant commodities and products it contains and, for wood, the scientific name of the species.
2. Quantity in the units used at customs, so that the statement can be matched to the shipment.
3. Country of production and, where the risk differs within a country, the region.
4. Geolocation of every plot on which the commodity was produced, with the date or time range of production. Plots up to four hectares can be given as a point with latitude and longitude, larger plots need polygons. For cattle, the geolocation of every establishment where the animals were kept. The information system accepts GeoJSON files in WGS 84.
5. Your suppliers: name, postal address and e-mail address of every business or person you sourced the commodity or product from.
6. Your customers: the same details for the businesses you supplied.
7. Evidence that the plots are deforestation-free: no conversion of forest to agricultural use after 31 December 2020 and, for wood, no forest degradation after that date.
8. Evidence of legal production: documents showing that the commodity was produced in accordance with the laws of the country of production, including the right to use the land.

The operator must keep this information for five years and produce it on request, so your customer will want it in a form that survives an audit: per product line, dated, with a named contact on your side. Certification schemes such as FSC, PEFC or RSPO can be used as supporting information in the risk assessment, but the regulation does not accept them as a substitute for the statement or the plot data.

The catch: products made from imported commodities

If you grow, harvest or raise the commodity yourself, the plots are your own and the exercise is a data-collection task. Most US exporters of relevant products do not: the cocoa in the chocolate, the natural rubber in the tyre, the tropical veneer on the furniture and often the pulp in the paperboard come from a supplier, and that supplier's supplier. The regulation does not care where in the chain the data sits. The plots that must appear in your customer's statement are the ones where the commodity was produced, wherever that is.

That turns the request upstream. You need the same eight items from your suppliers that your customer needs from you, per input, with the origin country and its risk classification. Coffee from Colombia and cocoa from Côte d'Ivoire come from standard-risk countries, which means the EU importer must run the full risk assessment and will ask for more than the minimum. Sector guides for the three chains where this bites most: EUDR for the timber industry, EUDR for coffee and cocoa and EUDR for rubber and tyres.

The calendar

The dates describe when your customer must file, not when the data has to be ready. A statement must exist before the customs declaration, and a statement rests on data that takes weeks to collect from a chain of suppliers. Importers that ship in the first week of January 2027 will want your files in the autumn of 2026.

At the border

Nothing changes in your US export declaration. On the EU side, the importer's customs declaration carries the reference number of the due diligence statement with document code C716; goods produced before 29 June 2023 are declared with Y132, transitional goods with C718, samples of negligible value and test material with Y187. Customs checks the presence and status of the statement, not its content, and does not release goods without it. Your contribution is upstream of that moment: the data must be with your customer early enough for the statement to be filed before the vessel arrives. Putting the lot or product-line reference on your commercial invoice and packing list makes the match between statement and shipment easier for everyone. The full list of codes is in EUDR TARIC codes.

How to organise it on your side

Treat it as a product-line file, not a shipment task. One file per product line contains the plots, the production periods, the supplier list and the evidence; a shipment then references the file. The information system allows one statement to cover several shipments over up to a year, so a stable file lets your customer file once and ship many times.

Collect from suppliers with a fixed format: GeoJSON for plots, a short supplier declaration for the deforestation-free and legality evidence, a contact per supplier. Check the geodata before it travels: coordinate system, plausibility of the location, polygon geometry, plot size against the four-hectare rule. Errors surface at submission or at customs, when the goods are already on the water.

Polygon One for exporters does this in one place: your suppliers deliver plots and documents into a portal without their own accounts, the platform checks every plot by satellite against the 2020 cut-off, and the result is one EUDR compliance certificate per product line with a GeoJSON package that every European customer can drop into a statement. Details on the EUDR for exporters page.

Frequently asked questions

Does the EUDR apply to companies in the United States?

Not directly. The obligations bind the operator, which is the first company established in the EU that places the product on the market, normally your importer. The importer needs data from you to comply, and will require it by contract.

Is the United States a low-risk country under the EUDR?

Yes. Implementing Regulation (EU) 2025/1093 classifies the United States as low risk. Your EU customer may then apply simplified due diligence under Article 13 and skip the formal risk assessment, but must still collect all Article 9 information, including the geolocation of every plot.

Do I need plot coordinates for every shipment?

For every plot on which the commodity in the shipment was produced. One statement can cover several shipments of the same product for up to a year, so a stable set of plots per product line is enough as long as nothing in the chain changes.

Can an FSC, PEFC or RSPO certificate replace the data?

No. Certificates can be used as supporting information in the risk assessment under Article 10, but the regulation requires the operator to hold the plot geolocation and the evidence itself.

What if my product is made from imported raw materials?

Then the plots that count are those of the raw material's origin, for example the cocoa farms in Ghana or the rubber plantations in Thailand. You need the same data from your suppliers that your customer needs from you.

What happens if I cannot provide the data?

Your customer cannot file a due diligence statement, the goods cannot be released in the EU, and the importer has to source elsewhere. Delisting is the practical consequence, not a fine against you.

Sources and status: Regulation (EU) 2023/1115 as amended by Regulation (EU) 2025/2650, Articles 2, 4, 6, 7, 9, 10, 13, 25, 26 and 38. Delegated Regulation (EU) 2026/2102 (Annex I). Implementing Regulation (EU) 2025/1093 (country benchmarking). DG TAXUD TARIC document on the EUDR, revision 1 of 23 September 2026. Commission FAQ on the EUDR. As at 27 September 2026. This article is not legal advice.