EU Deforestation Regulation (EUDR) is approaching: Is your business ready? 

The EU Deforestation Regulation (EUDR) was introduced to reduce the EU market’s contribution to global deforestation and forest degradation. It requires companies to ensure that specified commodities and products placed on or exported from the EU market are deforestation-free and legally produced. 

For most companies, the regulation starts to apply on 30 December 2026, while micro and small enterprises generally have until 29 June 2027. The extended transition does not apply to products already covered by the EU Timber Regulation. 

EUDR covers the commodities cattle, cocoa, coffee, oil palm, rubber, soy and wood, as well as specified products made from these. Whether an individual product is covered depends on whether the associated customs code is listed in Annex I of the Regulation. 

For the company the first practical questions are therefore clear: Which of our products are in scope, and what is our role for each product flow? 

What does deforestation-free mean, and when does EUDR apply? 

Two dates are important under EUDR, and they serve different purposes. 31th of December 2020 is the environmental cut-off date: the relevant commodity must not have been produced on land deforested after this date. For wood, the rules also cover forest degradation after this date. The product must also have been produced in accordance with the relevant legislation of the country of production. 

30th of December 2026 is the application date for most companies. From this date, the EUDR requirements must be applied when relevant products are placed on the EU market or exported. Micro and small enterprises have until 29 June 2027, except for products already covered by the EU Timber Regulation, for which the 30 December 2026 date applies. 

Companies should also review stock and work in progress held before 30th of December 2026. Check whether the product was first placed on the EU market before or after the rules start to apply. Purchase, production, customs, and sales records may be needed to establish the relevant timing. 

In Finland, proposed national EUDR legislation would complement the EU regulation with rules on supervision, authorities’ responsibilities and penalties. The government submitted the proposal on 8 October 2026, with entry into force intended for 30th of December 2026. 

Identify your role and check the EUDR Annex I product list 

An upstream operator first places a relevant product on the EU market or exports it from the EU. Next comes the first downstream operator or trader, which must retain the upstream due diligence statement references or simplified declaration identifiers. Downstream operators can place on the market or export products made from inputs already covered by DD-statements or declarations, while traders supply products already on the EU market further along the chain.  

Identifying a company’s EUDR role and clarifying the responsibilities attached to the role is an area where Ecobio has supported their clients. We help companies understand where their responsibilities begin and end, and how these fit with those of their suppliers and customers. Our advice focuses on what this means for your business and the product flows you work with. 

Other common questions we have encountered require a bit more interpretation and context assessment when applying the regulation, such as: 

  • Can we have more than one EUDR role? Yes. Your role depends on when and by whom the product was placed on the EU common market or exported. 
  • Does product processing change our EUDR responsibilities? It can. Check your role and the due diligence already completed upstream. 
  • How do we know which products are covered? Compare their customs codes with the latest EUDR Annex I documentation. 

EUDR and its guidance have evolved since adoption. Review earlier assessments against the latest consolidated EUDR regulation and Annex I, Commission FAQ, version 5, Commission guidance document, and Ruokavirasto’s EUDR guidance before finalising implementation.

What Does Due Diligence Under the EUDR Require?

Upstream operators must have a due diligence system and complete the required process before placing a relevant product on the EU market or exporting it. The process has three defined steps: 

  1. Information collection (Article 9): Gather product, origin and supply-chain data, including geolocation and evidence of deforestation-free, legal production. 
  1. Risk assessment (Article 10): Assess compliance risks using the collected information and statutory criteria. 
  1. Risk mitigation (Article 11): Reduce identified risks to negligible levels before placing the product on the market or exporting it. 

When all relevant commodities and products originate in countries classified as low risk, simplified due diligence may apply. The operator must still collect the required Article 9 information and assess the risk of circumvention or mixing. If information indicates possible non-compliance, the full risk assessment and mitigation process is required. 

The DDS or simplified declaration must be submitted through the EUDR Information System (TRACES) before the product is placed on the market or exported; see the official system guidance and user manuals. For imports, the reference must be available before the customs declaration is lodged, because the DDS reference number or simplified declaration identifier is included in the customs declaration. 

Detailed official descriptions are available in the Commission’s due diligence guidance.

A practical EUDR readiness check 

StepWhat to verify
1. Compare customs codes with Annex IList the customs codes for your own products, raw materials and processed products and compare them with Annex I. 
2. Map each product flow and role Identify where your legal entity imports, first places, processes, trades or exports relevant products. Assign the EUDR role separately for each flow. 
3. Confirm supplier information Check whether the required origin, geolocation, production-time and legality information is actually available for flows where you carry out upstream due diligence. 
4. Build the due diligence process Define how Article 9 information is collected, how Article 10 risk assessment is documented and how Article 11 mitigation is approved when needed. 
5. Define DDS and customs timing Ensure that the DDS is submitted and its reference available before placing on the market, export or lodging the relevant import customs declaration. 
6. Connect EUDR to systems and responsibilities Assign responsible persons. Ensure that procurement, customs clearance, production, inventory management and sales processes can record the required information and prevent transactions from proceeding if information is missing.
7. Test representative flows Test direct imports, EU purchases, continuous production, processing into a new customs code, old stock and exports before the application date. 

Prepare Now for the EUDR Requirements Applying from 30 December 2026

EUDR readiness is ultimately a process question: do you know which products are in scope, your role for each flow, and whether the necessary information and DDS reference will be available at the right time? 

Ecobio helps companies determine EUDR applicability, clarify roles, and build practical due diligence, risk-assessment and information-management processes.

Need support with EUDR implementation? Contact us to review your product scope and processes before the requirements apply! 

Aku Kähkönen 

Senior Consultant

aku.kahkonen@ecobio.fi 

+358 50 405 3322 
Ecobio Oy