EUDR for UK companies: who is caught, who is not, and what each situation asks of you

“Does the EUDR apply to us?” has no single answer for a UK company. A Leicestershire furniture manufacturer shipping to Dutch retailers, a Scottish sawmill with a customer in Cork, a Yorkshire chocolate maker selling online to Germany and a Midlands tyre distributor buying from Spain each get a different one. HMRC counted 126,029 UK businesses that exported goods in 2025 and 218,611 that moved goods to or from EU countries, and many of them are likely to handle something made of wood, paper, cocoa, coffee, rubber or beef.

The Regulation asks who places the goods on the EU market and who moves them across a customs border, and the answers can differ from one product flow to the next. Legal status as at 1 November 2026; the sources are listed at the end.

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What the Regulation says about non-EU companies

The EUDR binds operators, downstream operators and traders. It does not bind countries outside the EU (FAQ 1.30). A “third country” under Article 2(35) is any country or territory outside the customs territory of the Union. Great Britain has been outside that territory since 1 January 2021. Northern Ireland, for goods, is treated as if it were inside it.

An operator under Article 2(15) is anyone who, in the course of a commercial activity, places relevant products on the market or exports them, and who is not a downstream operator. The definition does not require establishment in the Union. For imports, the Commission Guidelines say the operator is, as a rule, the person named as importer in the customs declaration, data element 13 04 000 000. If that person is established in the UK, the UK company is the operator. Article 7 adds a second layer: where a person established outside the Union places products on the market, the first person established in the Union who makes them available is deemed to be an operator too. Recital 30 gives the reason: every supply chain should have an operator in the Union who can be held accountable.

For any given flow, a UK company is therefore the operator, a downstream operator or trader, the data supplier to its customer, or outside the Regulation altogether, which is what the eight scenarios sort out.

Which of your products are in scope

The seven commodities are cattle, cocoa, coffee, oil palm, rubber, soya and wood. The products sit in Annex I, as amended by Delegated Regulation (EU) 2026/2102, in force since 18 September 2026. Our Annex I page has the full table with CN codes, and a separate page covers the September amendments.

Wood mostly flows inwards. The UK imported £9.2 billion of wood products in 2024, and 97% of its sawn softwood by volume came from the EU (Forest Research). UK wood exports are small by comparison, but in 2025 paper and board shipped to the EU came to roughly £1.5 billion and furniture of all materials to roughly £1.2 billion (ONS). Ireland is the largest single destination for paper and board. For furniture the United States leads, France leads within the EU and Ireland comes third. Wooden furniture stays in scope, including ordinary wooden chairs, while seats for motor vehicles and aircraft were removed in September 2026.

Books and printed products under Chapter 49 were deleted by Regulation (EU) 2025/2650 in December 2025, so UK publishers and printers exporting finished books are no longer in scope for the book itself. The paper they buy still is, in the hands of whoever places it on the EU market. Raw hides, tanned hides and finished cattle leather were removed in September 2026. Beef, live cattle, offal and prepared beef products remain in.

Rubber is narrower since September 2026: retreaded tyres, conveyor and transmission belts (4010) and other articles of vulcanised rubber (4016) were taken out, and from heading 4012 only the tyre tread under 4012 90 30 remains. New tyres under 4011, natural and compounded rubber and several other rubber goods stay in.

Chocolate and everything else under 1806 is in scope because of the cocoa it contains, and the due diligence covers the cocoa, not the palm oil or the sugar. UK chocolate exports reached £1.0 billion in 2025 (FDF). Roasted coffee is in. Pallets, cartons and crates that carry something else are not relevant products while they do that job. Sold as goods in their own right, they are in scope.

Which date applies to you

30 December 2026. Articles 3 to 13, 16 to 24, 26, 31 and 32 apply from this date (Article 38(2)). That is every operator outside the deferral in Article 38(3), every downstream operator and trader whatever its size, and every product group except those added in September 2026.

30 June 2027. Operators that are natural persons or micro or small undertakings within the meaning of Article 3(1) or (2), first subparagraph, of Directive 2013/34/EU and were already established as such by 31 December 2024 get six more months (Article 38(3)). Until 29 June 2027 their customs declaration carries exemption code Y141 instead of a reference number. The thresholds are the EU accounting ones, in euros, not those of the UK Companies Act. Micro is two of balance sheet total up to €450,000, net turnover up to €900,000 and up to 10 employees. Small is two of €5 million, €10 million and 50 employees. The deferral does not apply to products covered by the Annex to the EU Timber Regulation, which is most wood and paper headings, so a small UK joinery acting as operator is in from 30 December 2026.

30 December 2027. Soluble coffee, the new palm oil derivatives including soap, and frozen cattle tongues.

31 December 2029, timber only. Timber under the EUTR Annex harvested before 29 June 2023 and placed on the market from 30 December 2026 stays under the EUTR through 30 December 2029 and must comply with the EUDR from 31 December 2029 (Article 37(2) and (3), read as in the table in chapter 3 of the Guidelines). Wood harvested from 29 June 2023 onwards is under the EUDR from 30 December 2026.

The EUTR is repealed with effect from 30 December 2026 (Article 37(1)). Until then, your EU customers importing UK timber work under the EUTR, which asks for legality and risk assessment but not for plot coordinates.

What the UK’s low-risk status changes

Implementing Regulation (EU) 2025/1093 of 22 May 2025 lists the United Kingdom of Great Britain and Northern Ireland as low risk, like every EU Member State, the United States, Canada, China and Japan. Our country risk page has the complete list.

Under Article 13, an operator placing products on the market that were produced exclusively in low-risk countries does not have to carry out the risk assessment of Article 10 or the risk mitigation of Article 11. Before relying on that, it has to assess the complexity of the supply chain and the risk of circumvention or of mixing with material from standard-risk or high-risk countries or of unknown origin. Article 9 and the Article 12 due diligence system remain, and it keeps documentation showing a negligible risk of circumvention or mixing. If information pointing to a risk turns up, Articles 10 and 11 apply again (Article 13(2)).

Geolocation therefore stays mandatory (Guidelines chapter 4(e)), and a Scottish forest block needs coordinates just as a Brazilian pasture does. Legality evidence is still required, proportionate to risk. The Guidelines say in-depth collection takes priority where an initial examination points to a higher risk. Where it shows a negligible risk, and the country classification counts here, no in-depth data collection is needed, but the information under Article 9(1)(h) must still be collected.

The commodity has to be grown or harvested in a low-risk country, and shipping it from Felixstowe is not enough. A UK roaster’s coffee may come from Colombia, which is standard risk, or from Vietnam, which is low risk. A UK furniture maker’s French oak and Latvian birch plywood also come from low-risk countries. The moment Colombian coffee is in the bag, the standard-risk rules apply to the whole product.

For an EU importer, UK-produced timber, beef or paper belongs to the easiest category of import it has, and the minimum annual check rate is lower: 1% under Article 16(10), against 3% for standard risk and 9% for high risk, with selection staying risk-based. The checks fall on the EU operator, not on the UK supplier.

Scenario 1: you sell to EU business customers and they import

This is the standard case for a UK manufacturer or merchant. Goods leave Great Britain under FCA, DAP or EXW terms, the EU customer or its forwarder lodges the import declaration, and the customer is the importer of record.

Your customer is the operator. It is as a rule the person in the importer field of the declaration, and the Guidelines generally tie the role to that field, regardless of change of ownership or contract terms. You are not an operator, a downstream operator or a trader, because you never place or make available anything on the Union market. A UK trading house is not a trader in this scenario either, although it can become one if it sells on goods already in free circulation within the EU.

The Regulation asks nothing of you. Your customer will ask for nearly everything in Article 9(1) (point (f) concerns its own buyers), because it cannot file its statement without it:

• a description with the trade name and, for anything containing wood, the common and full scientific name of every species that may be in it;
• the quantity in kilograms of net mass and, where applicable, the supplementary unit of the CN heading;
• the country of production and, where relevant, the region;
• the geolocation of every plot of land, with the date or time range of production: a point is enough for plots up to four hectares and for cattle establishments, above four hectares polygons are required, and all coordinates need at least six decimal digits (Article 2(28));
• your name, postal address and email address;
• adequately conclusive and verifiable information that the goods are deforestation-free and were produced in accordance with the relevant legislation of the country of production.

For UK-grown commodities the legality part of the last point is lighter than it sounds: the customer can work under Article 13, and where an initial examination shows a negligible risk the Guidelines do not call for in-depth data collection on legality. The information on deforestation-free status is not affected. For imported commodities inside your product, the data has to come from your own suppliers, and your customer’s procedure depends on the country of production. If everything comes from low-risk countries such as Sweden, Latvia, France or Ghana, it can work under Article 13. As soon as anything comes from a standard-risk country such as Ecuador, Colombia or Brazil, Articles 10 and 11 apply.

The statement has to exist before the customs declaration goes out (Article 26(4), FAQ 5.20), so your data has to be with the customer before the lorry boards the ferry. One statement may cover several shipments for up to a year (FAQ 5.19), so expect your larger EU customers to ask once a year for the plots behind a given volume, rather than per order. The Commission allows a “declaration in excess” only narrowly, for example for fully traced bulk commodities mixed in silos or mills, or for crop rotation (FAQ 1.18). The operator is then liable for every plot listed, one non-compliant plot makes the whole set non-compliant, and plot lists covering whole regions or countries are generally not acceptable.

You file nothing in this scenario. If a service provider offers you a “UK due diligence statement” as a substitute for your customer’s statement, ask what legal act it is filed under. There is none, and FAQ 3.10.2 says the Information System does not serve as a repository for products sold or further manufactured outside the EU. A data package can make your customer’s work easier, but it does not replace its statement.

Mixed-origin stock is the weak point. A UK timber merchant whose yard holds Scottish spruce next to Swedish and Latvian material, with no batch separation, cannot tell its Irish customer which plots are behind which pack. A single plot with deforestation after 31 December 2020 disqualifies everything from that plot (Article 9(1)(d)), FAQ 1.5 extends that to the whole mixed batch, and FAQ 1.4 rules out mass balance. Goods of unknown origin or non-compliant goods must be kept separate. Where compliant, traced goods stay mixed, every plot concerned has to be declared and checked.

Scenario 2: you clear the goods into the EU yourself

DDP terms, your own EU EORI number or an indirect customs representative acting for you can each put a UK company in the importer field, and it is then as a rule the operator. FAQ 3.7 says that a person established outside the EU who places relevant products on the EU market must exercise due diligence and submit a statement. In online sales, a company that imports is an operator “no matter whether such a company is established in the EU or not” (FAQ 3.18). If you sell to EU consumers and supply them yourself, you are the operator even if the consumer is named as importer on the declaration (FAQ 3.19).

As the operator you need:

• a due diligence system under Article 12, reviewed at least annually, with records kept for five years;
• information collection, risk assessment and risk mitigation under Articles 9 to 11, reduced to Article 9 by Article 13 if everything was produced in low-risk countries;
• a statement in the Information System before each release for free circulation, or one statement covering up to a year of shipments. Your customs representative needs the reference number (Article 26(4)), and without it, or a valid exemption code, the goods do not clear;
• a valid EORI number issued by an EU Member State or by the United Kingdom in respect of Northern Ireland, an XI number (FAQ 7.3). A GB EORI does not open the Information System. Non-EU companies register as operators (FAQ 3.7) and must also have their account validated by the support desk, copying the competent authority (User Guide v3.0, which excepts the United Kingdom in respect of Northern Ireland). For the customs declaration the number alone is not enough: without an establishment in Northern Ireland or the EU you need an indirect representative;
• if you are not an SME under the EU thresholds, a public annual report under Article 12(3), and under Article 11(2) a compliance officer at management level and an independent audit function, unless Article 13 removes Article 11.

For B2B deliveries under DDP, your EU customer stays in the picture. Article 7 makes the first EU-established person who makes the goods available a deemed operator, with the full obligations of an operator. In the cocoa example of FAQ 3.7, non-EU company A imports and must file a statement, and EU-based company B, which buys the beans and makes chocolate, is also an operator “and is equally obliged to exercise due diligence and submit a DDS”. That makes two statements and two due diligence files for one consignment. It applies where your customer makes the goods, or a relevant product made from them, available on the market. If it only uses them itself or turns them into a non-relevant product, Article 7 does not bite. In our assessment, a buyer caught by Article 7 has reason to refuse DDP from UK suppliers or to insist on an EU-established selling entity.

For B2C there is no deemed operator: under FAQ 3.7, Article 7 does not require an EU-established operator where the product goes to a final consumer. You carry the obligation alone, and FAQ 2.3 sets no minimum volume or value, so a £30 bag of roasted beans to a customer in Lyon counts.

Article 6 allows an operator to mandate an authorised representative to submit the statement, while the operator retains responsibility for compliance. The representative must be established in the Union (Article 2(22)). A company established in Great Britain cannot be one, but it can appoint one. Whether a company established in Northern Ireland can be one, the EU sources do not say expressly. The customs mandate is a separate document, as our article for freight forwarders and customs brokers explains.

A courier does not take this off your hands. Under DDP via an express operator, the express company acts as customs representative and will ask you for a reference number it has no way of producing. Our page on reference numbers with DHL, UPS and FedEx has the details.

Scenario 3: you have an EU subsidiary, a warehouse or a fulfilment partner in the EU

The operator is as a rule the entity in the importer field when the goods are released for free circulation. If that is your EU subsidiary, it is the operator and the UK parent is the data supplier, as in scenario 1. If the UK parent remains importer of record and the subsidiary then sells, you are back in scenario 2 with two statements, and FAQ 3.7 confirms that Article 7 applies “equally” to company groups with entities inside and outside the EU. The clean structure is therefore to let the EU entity import: one operator, one statement, and a due diligence system the group may maintain, while the EU entity stays responsible for it (FAQ 5.3).

Goods under customs warehousing, inward processing, transit or temporary admission are not placed on the market (Guidelines chapter 1(b)). Stock under bond in Rotterdam is outside the Regulation until the day it is released for free circulation, and on that day the statement must exist. Stock released before 30 December 2026 needs no statement, nor do products made entirely from it. The Guidelines say in chapter 3 that the operator’s duty is then limited to gathering “adequately conclusive and verifiable evidence” that the placing happened before the date, and dated import entries do that job. Wood and paper under the EUTR Annex reach the same result by another route: placed on the market before 30 December 2026, they and their derived products stay under the EUTR.

A 3PL that only stores and ships, without ownership or similar rights, falls outside the roles under chapter 2 of the Guidelines as long as it places or makes available nothing. FAQ 3.18, however, says fulfilment service providers usually do supply the product to the client and asks for a case-by-case assessment. So read the contract: who is the importer, who is the seller of record, who delivers.

Goods placed on the EU market, shipped to a UK customer and sent back are re-imports. An importer who can show the goods were previously on the EU market is a downstream operator, and at customs it gives its supplier’s reference number or, if it has none, a conventional reference number (FAQ 5.4, COM(2026) 191). Keep the original import entry and the export declaration together.

Scenario 4: you trade goods that never touch the UK

A London-based commodity trader buys cocoa in Côte d’Ivoire and sells it to a Dutch grinder, with the vessel sailing direct from Abidjan to Amsterdam. A UK timber agent sells Brazilian decking to a French builders’ merchant, shipped from Santos to Le Havre.

The EU importer is the operator, as in scenario 1. These goods come from standard-risk countries, so your customer must run the full Article 10 risk assessment and, where needed, Article 11 mitigation. It will want the Article 9 list from you and the material for that assessment: evidence on the producers, their legality documents, certification information and polygons.

You have nothing to submit because you place nothing on the EU market (FAQ 3.10.2), but you carry the commercial risk if the data is wrong. A statement that turns out to rest on a deforested plot leaves your customer exposed to Article 25 penalties and holding a product it may not sell. We expect contracts to push that risk back to you with warranties and indemnities. The Commission’s repository of relevant legislation by country of production, planned by December 2026, will help with legality but will not supply polygons.

Scenario 5: you import EU goods into Great Britain

Nobody on your side is an operator, whether you are a retailer buying Italian roasted coffee or a joinery buying Austrian glulam. Export from the Union is within the Regulation (Article 1 and Article 2(37)), so your EU supplier has an obligation at export. A supplier that bought the goods or its raw material on the EU market under an existing statement is a downstream operator at export, whether or not it processed them. Under the December 2025 amendment downstream operators file no statement of their own, and at export they use a dedicated TARIC code instead of a reference number (Article 26(4), last sentence, and FAQ 5.6.1). Only a supplier that is itself the first placer, such as an EU forest owner selling logs abroad, gives the reference number of its own statement at export or, as a micro or small primary operator, the identifier of its simplified declaration. You may or may not receive a reference number, since a downstream supplier has none of its own and no duty to pass one on to you.

The UK Timber Regulation, the EUTR as assimilated into UK law, does apply in Great Britain. A UK importer who first places timber on the GB market owes legality due diligence, with OPSS enforcing. The government’s UKTR report for 2022 to 2025, based on OPSS data, records a £240,000 fine for a boatbuilder over Myanmar teak and the first seizure notice, covering 26,767 items of furniture. The regime Defra is planning would add due diligence on all seven commodities for GB businesses with turnover above £1 million.

Sending the goods back into the EU changes your position. A GB wholesaler that sells Italian coffee on to Ireland and itself acts as importer into the EU must either show that the goods were previously placed on the EU market, making it a downstream operator that gives its supplier’s reference number or a conventional one, or treat them as a fresh placing with a full statement.

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Scenario 6: Northern Ireland, in both directions

The legal basis

Under the Windsor Framework, EU law on goods continues to apply in Northern Ireland, and under Article 13(3) a reference to a listed Union act is read as the act as amended or replaced. The EU Timber Regulation is listed in Annex 2, and the EUDR repeals and replaces it. Defra’s explanatory memorandum on the 2024 postponement, which also went before the Northern Ireland Assembly’s scrutiny committee, says the amending regulation “will apply in NI under Article 13(3) of the Windsor Framework”, subject to the democratic scrutiny mechanisms in Schedule 6B of the Northern Ireland Act 1998.

We have found no Joint Committee decision adding Regulation (EU) 2023/1115 to Annex 2; on this reading none would be needed. Whether the parts of the EUDR that go beyond the timber rules are “new elements” needing a separate step under Article 13(4) and an applicability motion came up in that committee on 9 January 2025, when DAERA said the EUDR had “not yet formally been added” and that the EU and the UK Government were “still in discussions”. We have found no public answer to that question. The policy paper of 23 June 2026 simply stated that the EUDR will apply in Northern Ireland and gave the reason: the agricultural sector there relies on cross-border supply and processing facilities on the island of Ireland.

Authorities and dates

The Office for Product Safety and Standards is the competent authority for wood and rubber products, DAERA for cattle, cocoa, coffee, palm oil and soya. Enforcement therefore sits with a UK body and a Northern Ireland department, under an EU regulation. The dates are the EU dates set out above.

Who is the operator in Northern Ireland

The UK guidance of 17 July 2026 uses a similar logic to the Commission. An operator is the first to place the product on the market “in the EU or Northern Ireland” or to export it from Northern Ireland to outside the UK and the EU. Its examples are a meat processor in Northern Ireland importing Brazilian beef, “a timber merchant based in Great Britain who sells wood products to a consumer in Northern Ireland”, and “a Northern Ireland coffee shop who buys coffee beans from a wholesale roastery in Great Britain”.

When a GB company sells to a Northern Ireland business and the buyer acts as importer, the buyer is the operator, as the Irish or German buyer would be. If the GB company acts as importer, it is the operator and the same logic as in scenario 2 applies. Whether the Northern Ireland buyer is then also an operator under Article 7 is not expressly stated in the sources. When a GB company sells to a Northern Ireland consumer, the GB company is the operator, so a Manchester furniture retailer with online customers in Belfast is in scenario 2 for those orders.

GB to NI, business to business

Northern Ireland bought £16.4 billion of goods and services from Great Britain in 2024, £13.0 billion of it goods (NISRA, provisional). The guidance says you should “gather and keep the information needed for them to comply”, identify which of your products are EUDR-compliant, and automate the sharing where you can.

It names the customer as the one completing the statement (“the information your customer needs to complete a due diligence statement”) and requires the sender to put the reference number or declaration identifier on the Internal Market Movement Information or the customs declaration. How the number gets from the customer to the sender it does not say.

A GB business that files the statement itself needs TRACES NT registration with an XI or EU EORI. For a customs declaration made in Northern Ireland, HMRC’s rules allow only a person established in Northern Ireland or the EU to be the declarant, so a business without such an establishment needs an indirect representative such as the Trader Support Service.

UKIMS with no duty, the IMMI and Trader Goods Profile, and the Northern Ireland Retail Movement Scheme remain available. The guidance is explicit that the EUDR requirement does not affect the ability to declare products as ‘not at risk’ of entering the EU. The EUDR obligations are not affected by that status.

GB to NI, business to consumer

Eligible parcels keep moving under the UK Carrier Scheme without customs, duty or safety and security declarations. The GB seller must give the statement’s reference number to the authorised carrier, which enters it in the “Supporting Document Reference Number” field of the business-to-consumer data set. Parcels outside the scheme carry the number in the Customs Declaration Service entry or go through the express operator’s door-to-door process. Either way, unless the Article 38(3) deferral applies to it, the GB seller has a statement to file first, and for that the guidance says it needs to be registered on TRACES NT with an XI or EU EORI number.

Other flows

Movements from Northern Ireland to Great Britain carry no EUDR requirement, and qualifying Northern Ireland goods keep unfettered access to the UK internal market.

Goods arriving in Northern Ireland from outside the UK and the EU need the reference number or declaration identifier in the customs declaration. UKIMS remains available for business deliveries. For consumer parcels the number goes into the Customs Declaration Service entry or to the express operator, with the UK Carrier Scheme where eligible.

Exports from Northern Ireland to third countries need the reference number or declaration identifier on the export declaration, as for an EU export. Downstream operators are exempt under Article 26(4) and use the dedicated TARIC code.

Goods that come back into Northern Ireland after being on the EU or Northern Ireland market need no new statement. The importer is a downstream operator, gives its supplier’s number or a conventional reference number, and keeps the evidence of the earlier placing and export for five years.

Northern Ireland producers

Northern Ireland sold £10.5 billion into the Republic of Ireland in 2024, £7.8 billion of it goods, and Ireland is its largest export market (NISRA, provisional). On the question of who places first, the guidance treats the Northern Ireland and EU markets together (“in the EU or Northern Ireland”), and the Regulation requires no new statement when goods already placed on the market in Northern Ireland are sold on into the Republic (Article 2(16)). Where the first sale is to a buyer in the Republic, that sale is the placing on the market: the NI seller is the operator and files before it sells, with no customs step to hang the reference number on.

A Northern Ireland beef farmer selling cattle to a local abattoir, or a private woodland owner selling logs to a Northern Irish sawmill, is a micro or small primary operator if it meets the size test, including where only the part of its business related to the relevant commodities stays below the thresholds (Article 2(15a)). It files a one-off simplified declaration rather than a statement per sale, and NI processors buying from it collect the declaration identifier.

What is still missing

In June Defra promised “further specific guidance on movements from Great Britain to Northern Ireland as soon as possible”. The guidance of 17 July and its updates of 24 July and 27 August supply the basic rules, but that sentence is still in the policy paper, and the guidance itself says Defra will “publish further guidance on moving EUDR-regulated products using these schemes”. At the time of writing, 1 November 2026, that has not appeared, and HMRC’s page for express operators moving parcels to Northern Ireland, updated on 1 November 2026, does not mention the EUDR at all.

Scenario 7: you are a UK farmer, forester or grower selling directly into the EU or Northern Ireland

Most UK primary producers sell to a UK processor or merchant and never meet the Regulation directly. A Scottish estate selling roundwood to a sawmill in Northern Ireland or a Cumbrian forestry business shipping logs to Ireland is a different case only if the producer itself is the importer of record, for example under DDP or with its own XI or EU EORI. Producers that sell to an EU or NI importer are in scenario 1. Larger producers that import themselves are in scenario 2.

A natural person or a micro or small undertaking under Directive 2013/34/EU, established in a low-risk country, that places products it has itself grown, harvested or raised is a micro or small primary operator under Article 2(15a). Establishment in the EU is not required. The Commission confirms the point for Norway in FAQ 9.13: such operators based in a third country “can benefit from the simplified regime laid out in Art. 4a EUDR”. Norway is a low-risk third country, and so is the United Kingdom. FAQ 3.21 adds that primary producers outside the EU are not in this category when they supply intermediaries outside the EU that then place the products on the EU market.

The simplified regime means a one-time simplified declaration in the Information System with the information in Annex III, a declaration identifier passed to the first downstream operator or trader, the option of a postal address instead of geolocation under Article 4a(5), and no risk assessment or mitigation unless something points to a problem. The producer still needs a due diligence system under Article 12 and the information of Article 9, and, where the goods cross a customs border, an EU or XI EORI number to register.

For cattle, Article 9(1)(d) wants the geolocation of all establishments where the animals were kept, which for a finished steer means the birth holding, every farm it passed through and the market it stood in; the UK guidance expressly names farms, abattoirs and cattle markets. AHDB says coordinates for every holding will be required in addition to the traditional movement and ear-tag data. It puts the EU’s share of UK beef exports at over 70%. The UK exported 113,000 tonnes of fresh and frozen beef worth £567 million in 2024, with Ireland the largest destination at 33,000 tonnes.

Scenario 8: you move, clear, store, certify or finance the goods

Freight forwarders, hauliers, customs agents and other logistics providers are not operators and not traders, as long as they hold no ownership or similar rights in the goods and do not themselves place, make available or export anything. The Guidelines say so in chapter 2 and name forwarders, shipping agents and customs representatives. The same reasoning would seem to apply to inspection bodies, certification schemes and lenders, but they are not named there. FAQ 3.15 adds that customs representatives are never operators, “whatever the circumstances”.

The person lodging the EU import declaration has to make the reference number available to customs (Article 26(4)), so a UK forwarder is the first to find out when an exporter’s customer has not filed. Our article for freight forwarders and customs brokers covers the data elements and the fifteen TARIC document codes. Online marketplaces sit in the same category under FAQ 3.18, as long as they only bring buyer and seller together. A platform that also stores, ships or sells is judged function by function.

The regime Great Britain is planning

Schedule 17 of the Environment Act 2021 gave ministers the power to require due diligence on “forest risk commodities”. After consultations in 2020 and in 2021 to 2022, Defra settled at the time of COP28, in December 2023, on cattle products other than dairy, cocoa, palm oil and soya, a global turnover threshold of £50 million, and a test of whether the commodity had been produced in breach of local law. Timber was excluded by the Act itself: paragraph 1(6) of Schedule 17 says the regulations “may not specify timber or timber products”. Legislation.gov.uk shows no regulations under Schedule 17, only commencement regulations S.I. 2022/518, which brought the power into force.

On 23 June 2026 Defra published “The UK’s approach to deforestation regulations”. The paper states aims and intentions and changes the main parameters of the earlier design:

• Scope: wood, cattle, cocoa, coffee, palm oil, rubber, soya, and “certain derived products like chocolate and furniture”, the same seven commodities as the EUDR. Which products are covered is to be set out in the consultation, according to written answers of 30 June and 14 October 2026.
• Who: businesses in Great Britain with an annual turnover of over £1 million that use forest risk commodities and wood products.
• What: a due diligence system, reporting, and proof of compliance “by collecting geolocation data about the origin of the specific products”.
• Standard: production “in compliance with relevant local laws”, so legality rather than deforestation-free, with the stated intention “in due course” to “move towards a deforestation-free standard”.
• Alignment: the aim that “the information GB businesses must hold will be broadly the same as what is needed for a due diligence statement when exporting to the EU or moving goods to Northern Ireland under the EUDR”.
• Timing: consultation to follow, legislation “expected” to be delivered in 2027. Defra’s own slides for the UK Sustainable Commodities Initiative (UKSCI) session of 9 July 2026 add implementation in 2028, to be confirmed, on an indicative timeline.

The paper also says the government will strengthen the UK Timber Regulation. If wood is to come into the Schedule 17 regime, the Act has to be amended, since it currently excludes wood; Mayer Brown’s note of 3 August 2026 flags this. Wood could also be dealt with through the strengthened UK Timber Regulation. Mayer Brown adds that it is unclear whether the change of Prime Minister will bring further delay or another rethink. The UK Trade Policy Observatory wrote a month later that the change could redirect the policy, but that pressure from NGOs and business could also carry the rules forward. The consultation promised for “later this year” had not opened by 1 November.

The data set you are assembling for your EU customers now is, on Defra’s stated aim, broadly the data set you will need for your own GB compliance once the regime applies, on the indicative timeline from 2028. The GB regime is planned to ask for legality and the EUDR asks for legality plus deforestation-free, so the EU standard is the superset. A company that meets the EUDR data requirements should not have to start again for Defra, if that aim survives the consultation.

What to do before 30 December 2026

Each item names the scenarios it belongs to.

1. Map every flow of relevant products by Incoterm and by importer of record. This shows whether you are in scenario 1, 2 or 3, and whether Article 7 doubles anything. (All scenarios.)
2. Classify your products against Annex I as in force since 18 September 2026. Check seats, leather, retreaded rubber and printed matter, which moved, and flag the 30 December 2027 additions. (All.)
3. Size your company against Directive 2013/34/EU, in euros. The position on 31 December 2024 decides whether you, as a natural person or a micro or small undertaking, have until 30 June 2027 for products outside the EUTR Annex. (Scenarios 2, 3, 6, 7.)
4. Decide the importer of record for every EU and NI flow. If your customer or your EU entity imports, you avoid being an operator and you avoid the Article 7 doubling. (Scenarios 2, 3, 6.)
5. Get the right EORI number and register. You need an EU EORI from a Member State customs authority or an XI EORI, then a registration as operator or an EU-established authorised representative under Article 6. The UK guidance adds TRACES NT registration for GB businesses moving goods to NI. (Scenarios 2, 3, 6, 7.)
6. Build the Article 9 data pack per product. For commodities from low-risk countries this is the core of the file under Article 13, together with the assessment of complexity and circumvention risk. For commodities from standard-risk or high-risk countries it is the start of the risk assessment. (Scenarios 1 to 7.)
7. Chase your own suppliers now, and put the data obligation into the purchase contract. (Scenarios 1, 2, 4.)
8. Separate stock. Goods of unknown origin or non-compliant goods must not be mixed with compliant goods (FAQ 1.4). Mixed compliant goods can only be declared if every plot concerned is listed and checked. Separate EU stock released for free circulation before 30 December 2026 from stock released after. (Scenarios 1, 3.)
9. Write the due diligence system down. Article 12 wants a documented framework, reviewed yearly, with records for five years, even for an operator that only sources from the UK. (Scenarios 2, 3, 6, 7.)
10. Brief your forwarder and your couriers, and amend your terms. Tell them who the operator is for each flow and where the reference number comes from. Put data delivery deadlines, warranties on origin and the cost of a rejected consignment into the contract. (Scenarios 1, 2, 4, 6, 8.)
11. Keep one eye on Defra. The GB consultation is due, legislation is expected in 2027, and further GB to NI guidance is promised “as soon as possible”. (All.)

Frequently asked questions

Does the EUDR apply to companies in the United Kingdom?

Not because they are in the UK. Great Britain is a third country under Article 2(35). A UK company is bound when it takes on a role under the Regulation. It is an operator above all when it releases relevant products for free circulation in the EU or Northern Ireland, supplies them to consumers there, or is the first to place goods produced in Northern Ireland on the market there. If it sells on goods already on the EU or Northern Ireland market, it is a trader. If it re-imports such goods or places products made from them on the market, it is a downstream operator. When the EU customer imports, the customer is the operator and the UK company supplies the data.

Does the EUDR apply in Northern Ireland?

Yes, from 30 December 2026. The UK government treats the EUDR as applying in Northern Ireland under the Windsor Framework and confirmed it on 23 June 2026. OPSS is the competent authority for wood and rubber products, DAERA for cattle, cocoa, coffee, palm oil and soya. The EUDR does not apply in Great Britain.

Is the UK a low-risk country under the EUDR?

Yes, in Implementing Regulation (EU) 2025/1093. Operators placing goods on the EU market that were produced exclusively in the UK or other low-risk countries can use simplified due diligence under Article 13: no risk assessment or mitigation once complexity and circumvention risk have been assessed, but the full information requirements of Article 9 including geolocation.

Who submits the due diligence statement when a UK company sells to a German customer?

The German importer, if it is the importer of record. A UK company that is not the importer does not submit a statement (FAQ 3.10.2). If the UK company is the importer, for example under DDP, it submits the statement as a non-EU operator and the German customer must also file one under Article 7 if it makes the goods available on the market.

Does a UK company need to register in the EU Information System?

If it is an operator, for example because it imports into the EU or Northern Ireland itself or supplies consumers there, or if it is a non-SME downstream operator or trader, for example a large UK company re-importing goods previously placed on the EU market or selling on goods already in free circulation in the EU (Article 5(2)). An importing operator needs an EU EORI number or an XI EORI number; a GB EORI is not accepted (FAQ 7.3). It may mandate an EU-established authorised representative under Article 6 to submit on its behalf, and the number still goes into the statement (Annex II).

What about selling online to EU consumers from the UK?

The UK seller is the operator when it supplies the goods to the consumer, even if the consumer is named as importer on the declaration (FAQ 3.18 and 3.19). There is no deemed EU operator for consumer sales, so the UK company carries the obligation alone, and the parcel will not clear without a reference number or a valid exemption code.

What are the dates for small UK companies?

Operators that are natural persons or micro or small undertakings under Directive 2013/34/EU and were already established as such by 31 December 2024 apply the rules from 30 June 2027 instead of 30 December 2026, except for wood and paper products covered by the Annex to the EU Timber Regulation. The thresholds are in euros: small means not exceeding two of €5 million balance sheet, €10 million turnover and 50 employees.

What is the UK Forest Risk Commodities regulation, and when does it start?

Defra said on 23 June 2026 that it aims to introduce due diligence in Great Britain on wood, cattle, cocoa, coffee, palm oil, rubber and soya and derived products for businesses with turnover above £1 million, based on legality in the country of production and backed by geolocation data. A consultation is to follow, legislation is expected in 2027, and Defra’s slides of 9 July 2026 indicate implementation in 2028, to be confirmed.

Can a UK company act as an authorised representative?

Not if it is established in Great Britain. Article 2(22) requires the authorised representative to be established in the Union. A UK operator can appoint one. Whether a company established in Northern Ireland can be one, the EU sources do not say expressly.

Further reading

• EUDR for US exporters: what EU buyers ask from 30 Dec 2026
• EUDR country risk: every country and its classification
• EUDR for freight forwarders: declarations, codes, liability
• EUDR: trader or operator? Roles, SME thresholds, deadlines
• EUDR geodata: requirements, formats, validation, template

Sources and status: Regulation (EU) 2023/1115 as amended by Regulation (EU) 2024/3234, Regulation (EU) 2025/2650 and Delegated Regulation (EU) 2026/2102, consolidated text of 18 September 2026, Articles 1, 2, 3, 4, 4a, 5, 6, 7, 8, 9, 10, 11, 12, 13, 16, 25, 26, 37 and 38 and Annexes I, II and III. Commission Implementing Regulation (EU) 2025/1093 of 22 May 2025. Commission Guidelines, OJ C/2026/3896 of 20 July 2026, chapters 1, 2, 3, 4, 6, 7, 9 and 10. Commission FAQ, fifth iteration (April 2026, published 4 May 2026, in the version of August 2026), questions 1.4, 1.5, 1.8, 1.18, 1.30, 2.3, 3.1, 3.7, 3.10, 3.10.2, 3.15, 3.17, 3.18, 3.19, 3.21, 3.24, 5.4, 5.5, 5.6.1, 5.17, 5.19, 5.20, 7.3, 9.1, 9.2 and 9.13. EUDR User Guide for Economic Operators, version 3.0. DG TAXUD, TARIC data for Regulation (EU) 2023/1115, revision of 23 September 2026. Commission simplification review COM(2026) 191 of 4 May 2026. Windsor Framework, Articles 4, 5, 6, 13 and Annex 2. Defra, “The UK’s approach to deforestation regulations”, policy paper of 23 June 2026, updated 2 September 2026. Written Ministerial Statement HCWS137 of 23 June 2026. Defra, “Moving, exporting or placing deforestation-free products on the market in Northern Ireland”, guidance of 17 July 2026, updated 24 July and 27 August 2026. Defra, explanatory memoranda on Regulation (EU) 2024/3234 (8 January 2025) and Regulation (EU) 2025/2650 (20 January 2026). Northern Ireland Assembly, Windsor Framework Democratic Scrutiny Committee, Official Report of 9 January 2025. Defra slides for the UK Sustainable Commodities Initiative (UKSCI) session of 9 July 2026. Environment Act 2021, Schedule 17; S.I. 2022/518; Written Ministerial Statement HCWS117 of 12 December 2023; Defra, news story of 9 December 2023. Written answers UIN 12419 (30 June 2026), UIN 31083 and UIN 32384 (14 October 2026). Defra, UKTR report 2022 to 2025 (12 August 2025), data from OPSS. Directive 2013/34/EU, Article 3, as amended by Delegated Directive (EU) 2023/2775. HMRC, Customs Importer and Exporter Population 2025 (16 April 2026); Get an EORI number; CDS Declaration Completion Instructions, Group 3; How to move parcels from Great Britain to Northern Ireland for express operators (1 November 2026). Food and Drink Federation, Trade Snapshot 2025. ONS, trade in goods: country-by-commodity exports, release of 15 October 2026, annual values for 2025. Forest Research, Forestry Statistics 2025. NISRA, Northern Ireland Economic Trade Statistics 2024 (provisional). AHDB, EUDR guidance and 2024 beef trade review (28 February 2025). Mayer Brown, note of 3 August 2026; UK Trade Policy Observatory, blog of 4 September 2026. As at 1 November 2026. This article is not legal advice.

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