EU Deforestation Regulation: what applies to companies from 30 December 2026

From 30 December 2026, large and medium-sized companies that place cattle, cocoa, coffee, oil palm, rubber, soya or wood on the EU market, or export them, must be able to show that these commodities are deforestation-free and legally produced. The same applies to products made from them, such as pulp, paper, furniture, charcoal, tyres, chocolate and beef. The EU Deforestation Regulation (EUDR), Regulation (EU) 2023/1115, was postponed twice and amended in December 2025; the Commission has since revised the product list without reopening the regulation. Most micro and small operators follow on 30 June 2027.

What the regulation requires

Relevant commodities and products may only be placed on the EU market, made available or exported if they are deforestation-free, produced in line with the relevant legislation of the country of production, and covered by a due diligence statement or, for the smallest producers, a simplified declaration (Article 3, as amended). ‘Deforestation-free’ means produced on land not deforested after 31 December 2020; for wood, also harvested without causing forest degradation after that date (Article 2(13)).

Operators carry the main burden. Before placing products on the market or exporting them, they must:

• collect information on the product, suppliers and buyers, including the geolocation of all plots of land where the commodities were produced (Article 9);
• assess the risk of non-compliance, including the country’s risk level, and review that assessment at least once a year (Article 10);
• mitigate any risk that is more than negligible, for instance by requesting more information or commissioning independent audits (Article 11);
• submit a due diligence statement through the EU Information System.

Where all commodities come from low-risk countries, operators may apply simplified due diligence and skip the risk assessment and mitigation, unless they have information pointing to non-compliance (Article 13). Under Implementing Regulation (EU) 2025/1093, four countries are high risk (Belarus, Myanmar, North Korea and Russia). Some 140 are low risk, including all EU Member States, the United States, the United Kingdom, Canada and China. All others, including Brazil, are standard risk.

Each year, national authorities must check at least 1%, 3% or 9% of operators, non-SME downstream operators and non-SME traders, depending on country risk (Article 16). Penalties must include maximum fines of at least 4% of annual EU-wide turnover, confiscation of products and revenues, and temporary exclusion from public procurement and public funding (Article 25).

What has changed since 2023

Adopted in 2023, the regulation was due to apply from 30 December 2024. It was postponed twice, most recently by Regulation (EU) 2025/2650 of 19 December 2025, which also redistributed obligations along the supply chain. In 2026 the Commission added a simplification review, updated guidance and two implementing measures.

The Commission estimates that these changes cut annual compliance costs by about 75% compared with the original regulation.

Who has to do what

The amended regulation distinguishes three roles, and the same company can hold different roles for different products.

• Operators place relevant products on the EU market for the first time, by importing or producing them, or export them. They carry out due diligence and file the statement (Article 4).
• Downstream operators place on the market or export relevant products made using other relevant products, such as a furniture maker using timber bought in the EU. They must hold information on their suppliers and on the businesses they supply; only those buying directly from an operator need to keep the reference number of the due diligence statement or simplified declaration. Records are kept for five years (Article 5).
• Traders, such as distributors and wholesalers, make relevant products available without being an operator or downstream operator. The same record-keeping duties apply.

Non-SME downstream operators and traders must also register in the Information System. If they receive information suggesting non-compliance, they must notify the authorities and may only place the product on the market once they have verified that the risk is no more than negligible (Article 5(6)). Under the Commission’s guidance, companies may rely on their supplier to pass on the reference number, and invoices can serve as records.

Where the file stands (28 October 2026)

• Legislation. The Commission’s simplification report of 4 May 2026 concluded that the regulation does not need to be reopened. At the time of writing, no proposal to move the application dates again has been tabled.
• Pressure from abroad. The US administration lobbied for a ‘no-risk’ country category; 32 Democratic members of the US House of Representatives urged the opposite. The Commission did not create one.
• Product scope. Delegated Regulation (EU) 2026/2102, adopted on 13 July 2026, drew no objection from Parliament or Council and entered into force on 18 September 2026.
• Information System. It reopened at the end of June 2026. An implementing act of 13 July 2026 adds simplified declarations and updates the technical specifications for automated connections (APIs). The Commission offers training to companies.
• Still to come. Before the end of 2026, the Commission plans to publish repositories of relevant legislation in producing countries and of certification schemes.
• Key dates. 30 December 2026: application for large and medium-sized companies and for micro and small timber operators, and repeal of the Timber Regulation. 30 June 2027: other micro and small operators. 30 December 2027: newly added products. 30 June 2030: the Commission’s general review (Article 34).

What it means in Belgium

• Who checks. The competent authority is the deforestation inspection unit of the Federal Environment Inspectorate, within the FPS Public Health, Food Chain Safety and Environment. The FPS’s Directorate-General Environment leads the project, acts as contact point and represents Belgium in EU committees, Minister Jean-Luc Crucke told the Chamber’s environment committee on 6 January 2026.
• Federal and regional roles. The Interministerial Conference on the Environment has divided the work between the federal level, the regions and the communities. Regional agriculture and environment administrations and the food safety agency FASFC, through its Sanitel livestock database, are examining how to support operators of wood, soya and cattle. DG Environment will publish, with the regions, a list of Belgian legislation relevant to the legality requirement.
• Belgian producers. Belgium is low risk, so operators placing Belgian wood or cattle on the market can apply simplified due diligence. Micro and small primary producers can file a one-off simplified declaration, or need not file one where the data already sit in a national system made available to the Information System (Article 4a(4)).
• Penalties. Belgium set its penalty regime in 2024 by amending the Product Standards Law of 21 December 1998. According to law firm Altius, infringements can lead to prison sentences of up to three years, fines of up to €4 million, recall or destruction of products, or an administrative fine.
• Belgium’s position. The minister supports simplification provided it does not ‘denature the spirit of the text’, and said Belgium did not support the final text of the December 2025 amendment because it fell short of that requirement.
• Support. VLAIO offers a practical guide for SMEs and advice through Enterprise Europe Network Flanders. The FPS and Fairtrade Belgium organised a webinar on EUDR inspections on 27 October 2026.

What to do now

1. Check every product code. Compare your CN codes with Annex I as amended in December 2025 and by Delegated Regulation (EU) 2026/2102. Some products have left the scope; others enter it on 30 December 2027.
2. Map your role, product by product and entity by entity. Whether a company is an operator, downstream operator or trader, and whether it is an SME, decides what it must do and from when. Group structures and imports handled by another group company deserve particular attention.
3. Operators: close the data gaps now. Geolocation and legality evidence must come from suppliers before 30 December. Build these requirements into contracts, register in the Information System, test the submission of due diligence statements and use the Commission’s training.
4. Downstream operators and traders: set up records and a procedure for concerns. Keep supplier and customer data, and reference numbers where relevant, for five years. Non-SMEs must register and need a procedure for acting on information that suggests non-compliance.
5. Plan for 30 December and keep talking to the authorities. Decide what happens to stock and running contracts. Raise questions about inspections now with the Federal Environment Inspectorate, directly or through your sector federation, and document practical problems: they are the evidence for future guidance and reviews.

Sources

1. EUR-Lex, Regulation (EU) 2023/1115 on the making available on the Union market and the export from the Union of certain commodities and products associated with deforestation and forest degradation, 31 May 2023 (Articles 2, 3, 9, 10, 11, 13, 16 and 25).
2. EUR-Lex, Regulation (EU) 2025/2650 of 19 December 2025 amending Regulation (EU) 2023/1115 as regards certain obligations of operators and traders, Official Journal of 23 December 2025 (Articles 2(15a), 2(15b), 4a, 5, 16, 34, 37 and 38 of the amended regulation).
3. EUR-Lex, Commission Delegated Regulation (EU) 2026/2102 of 13 July 2026 amending Regulation (EU) 2023/1115 as regards the list of relevant commodities and relevant products, in force since 18 September 2026.
4. European Commission, Commission updates product scope and tools to support EUDR, 13 July 2026.
5. Belgian Chamber of Representatives, Committee on Energy, Environment and Climate, integral report of 6 January 2026, question 56011236C by Marie Meunier and answer by Minister Jean-Luc Crucke.
6. VLAIO, EUDR: bereid je onderneming voor op de nieuwe regels rond ontbossingsvrije producten, 17 September 2026.
7. Linklaters, EU: EUDR simplification report lands alongside updated guidance and FAQs, May 2026.
8. Baker McKenzie, EU Commission publishes simplification review of EUDR, 8 May 2026.
9. Arendt, EUDR simplification review published: what the 2026 package means for in-scope companies, 18 May 2026.
10. Fieldfisher, The EU Deforestation Regulation: European Commission classifies countries as high, low or standard risk, 9 July 2025 (on Implementing Regulation (EU) 2025/1093).
11. Ploum, EUDR postponed and simplified: what Regulation (EU) 2025/2650 really changes, 5 January 2026.
12. BDO Belgium, EU Deforestation Regulation (EUDR), information sheet, 2026.
13. Altius, Belgium gears up to enforce the EU Deforestation Regulation, 20 June 2024.
14. Green Queen, EU confirms 2026 deadline for Deforestation Regulation amid US pressure, 5 May 2026.
15. Fairtrade Belgium, Webinar: EUDR-inspecties in België, 27 October 2026.

This analysis reflects the state of the file on 28 October 2026. We update it when the file moves.