EUDR (EU Deforestation Regulation): Who Must Comply, the Due Diligence Statement and Key Dates

The EUDR is Reglamento (UE) 2023/1115 (the EU Regulation on deforestation-free products). A covered product may only be placed on the Union market, made available on it or exported if it meets 3 conditions: it is deforestation-free, it has been produced in accordance with the relevant legislation of the country of production, and it is covered by a due diligence statement or, for small primary producers, by a simplified declaration.

Deforestation-free means that the relevant commodity comes from land that has not been converted from forest to agricultural use after 31 December 2020; for wood, it also means that it has been harvested without inducing forest degradation after that date.

There are 7 relevant commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood. What governs scope is Annex I, which lists products by Combined Nomenclature (CN) code: chocolate, palm derivatives, soya flour, tyres, paper, furniture and beef are included because they contain or have been made using those commodities. If your code is not in Annex I, that product is not covered.

Annex I has changed twice in 10 months. Printed products were removed in December 2025. Since 18 September 2026, bovine hides and skins, soya beans for sowing, several rubber articles and certain seats have been removed, and most used products, samples, bamboo and rattan are excluded. From 30 December 2027, instant coffee and several palm derivatives are added. The table in this guide summarises these changes.

It does not apply to goods produced before 29 June 2023 (date of harvesting or, for cattle, date of birth) if the operator can prove this, nor to goods produced entirely from material that would otherwise have been discarded as waste.

The primary obligation falls on the operator: any person who, in the course of a commercial activity, places a covered product on the Union market for the first time or exports it. This is the importer, the exporter or the EU producer selling what they harvest or raise. If the seller is established outside the Union, the first person established in the Union who makes the product available on the market is deemed to be the operator.

Following the 2025 reform, a downstream operator (who places on the market or exports products made using other products already covered by a statement, such as a chocolate manufacturer buying cocoa from an importer) and a trader (distributors, shops, retail chains) do not submit a due diligence statement. They must keep for at least 5 years the details of their supplier, including the reference number of the supplier's statement, and those of their business customer. If they are non-SMEs, they must also register in the information system before operating.

A micro or small primary operator is a natural person, micro-enterprise or small enterprise established in a low-risk country selling what they themselves grow, harvest or raise there. Spain is classified as low risk, so many cattle farmers and forest owners in Spain fall into this category. They submit a one-off simplified declaration, and do not even need to do that if their data are already recorded in an official national database that the Member State feeds into the system.

Anyone who merely transports goods or handles customs clearance is not an operator provided they do not place products on the market or export them on their own account: liability lies with the operator who places the product on the market or exports it.

The dates of 30 December 2025 and 30 June 2026 that still circulate online are no longer valid: Reglamento (UE) 2025/2650 postponed them by 12 months. Today, the EUDR applies from 30 December 2026, and from 30 June 2027 for natural persons, micro-enterprises and small enterprises that already held that status on 31 December 2024.

There is an exception that catches many timber SMEs off guard: if your product is listed in the Annex to the former EU Timber Regulation (EUTR), the application date is 30 December 2026 regardless of your company's size. The EUTR is repealed on that date, continuing to apply until 31 December 2029 only to timber produced before 29 June 2023.

According to the European Commission's FAQs, products placed on the market before their respective application date do not have to comply with the EUDR, and anyone who subsequently manufactures another product from them only needs conclusive and verifiable evidence of that placement date. Start archiving invoices and customs clearance documents now.

Do not count on another delay: in its review report of 4 May 2026, the Commission ruled out proposing any further changes to the legislative text.

The due diligence statement (declaración de diligencia debida, or DDD) is the operator's formal declaration in the EU information system that due diligence has been exercised and that no or only a negligible risk was found. It is submitted before placing a product on the market or exporting it, and by submitting it the operator assumes responsibility for the product's compliance. The Regulation does not charge any tasa (official fee) for submitting it.

Its required contents (Annex II) are: the operator's details and EORI number; the Harmonised System code, description, scientific name if the product contains wood, and net mass in kilogrammes; the country of production and geolocation of all plots of land; and the signed declaration. If you do not yet have an EORI number, our guide to importing and exporting explains how to obtain one.

The system is built into the European Commission's TRACES platform. You log in with an EU Login account and register an economic operator profile specifying your role: operator, trader or authorised representative. Only submissions on the LIVE server are valid; anything filed in ACCEPTANCE, the testing environment, does not cover any shipment.

Each DDD is assigned a reference number and a verification number. According to MITECO (Spain's Ministry for the Ecological Transition), a statement can only be amended or withdrawn within 72 hours of submission, and never once its reference number has been used in a customs declaration. That reference number must be made available to customs before release for free circulation or export. The customs declaration itself is lodged by your company or a registered customs representative; we prepare the DDD numbers for you so they can be entered on the declaration.

You do not have to file it yourself. An operator may give a written mandate to an authorised representative established in the Union, which is separate from customs representation, while the operator remains responsible for the product's compliance. Managora acts as your authorised representative using our own TRACES account, without asking for your digital certificate.

This is the hardest piece of data to gather. It must be provided as latitude and longitude coordinates with at least 6 decimal places; plots of land over 4 hectares, except for cattle, must be mapped as polygons, while smaller plots can be identified by a single point. For cattle, you provide the geolocation of all establishments where the animals were kept. TRACES accepts GeoJSON files in WGS-84 (EPSG-4326): a PDF map or coordinates with 4 decimal places will not be accepted.

In addition, the operator must keep for 5 years the product description and quantity, the country and date of production, the details of suppliers and business customers, and evidence that the product is deforestation-free and legally produced in its country of origin.

A sustainability certificate does not replace geolocation: the Regulation treats certification schemes as complementary information for risk assessment. Micro and small primary operators may provide the postal address of the plot of land or establishment instead of coordinates.

Reglamento de Ejecución (UE) 2025/1093 (the Implementing Regulation on country benchmarking) classifies Belarus, Russia, Myanmar and North Korea as high risk, and classifies Spain and the rest of the EU, China, the United States, India, Vietnam and Ukraine, among others, as low risk. All other countries are standard risk, including Brazil, Indonesia, Malaysia, Côte d'Ivoire and Colombia.

Full due diligence has 3 steps: collecting information, assessing risk and mitigating risk until there is no or only a negligible risk. The risk assessment must be documented, reviewed at least once a year and made available to the competent authorities upon request.

If all relevant commodities and products originate in low-risk countries, simplified due diligence applies: you do not need to carry out risk assessment or risk mitigation, provided you can demonstrate that the risk of circumvention or mixing with products of other origins is negligible, and you must still submit a DDD. If origins are mixed or you obtain information pointing to possible non-compliance, the full due diligence procedure applies.

Every operator must maintain a due diligence system, review it once a year and keep the records for 5 years; non-SME operators must also publicly report on their due diligence system every year.

Spain's national competent authority is the Directorate-General for Biodiversity, Forests and Desertification within MITECO, and each autonomous community has designated its own regional authority: a forestry, environmental, agricultural, or trade and consumer affairs body, depending on the region. MITECO published the full list in March 2026.

Each year, authorities must check at least 1%, 3% or 9% of operators and of non-SME downstream operators and traders, depending on whether the country of production is low, standard or high risk; for high-risk countries, checks must also cover 9% of the volume of each relevant product. Customs will suspend release if requested by the competent authority and refuse it if the product is non-compliant: customs release alone does not prove EUDR compliance.

Penalties are laid down by each Member State subject to EU minimum standards: fines with a maximum threshold of at least 4% of the legal person's total annual Union-wide turnover, confiscation of the products and of the revenues gained, exclusion from public procurement and public funding for up to 12 months, and a temporary prohibition from placing or making available products on the market, or exporting them, in the event of a serious or repeated infringement.

As of 15 October 2026, no Spanish Act has been published in the BOE (Official State Gazette) setting out the domestic schedule of EUDR offences, only a draft bill reviewed on 17 June 2025 that sets up the Office for Combating Trade-Related Deforestation. That does not delay anything: as an EU Regulation, the EUDR is directly applicable. If you face an inspection, an official information request or a corrective measure, Managora handles the file and submits written submissions (alegaciones) on your behalf under your power of attorney.

What takes the most time is not filing the statement in TRACES, but obtaining geolocation files and legality evidence from your suppliers. The practical order of work is: cross-check your CN codes against the version of Annex I currently in force, determine your role in each supply flow and your company size on 31 December 2024, and start requesting the data from your suppliers now, adding a contractual clause requiring them with every shipment.

Managora carries out your scope assessment and submits your due diligence statements or simplified declaration in TRACES as your authorised representative under a written mandate. For non-SME downstream operators and traders, we prepare the registration so you only have to sign it with your EU Login. You can see the current fee on the service page.