EU compliance

EUDR: first establish whether you are affected. Then implement with focus.

Regulation (EU) 2023/1115 prohibits placing on the EU market or exporting products linked to deforestation after 31 December 2020. More companies are affected than expected, because products made from the commodities count as well. This page answers the three questions that come first.

Am I affected?

Three things decide it: your product, your activity and your position in the supply chain. None of them can be read off the product name.

  • Seven commodities: wood, cocoa, coffee, rubber, oil palm, soy and cattle – plus products made from them under Annex I, such as furniture, tyres and chocolate. Books and printed matter (heading ex 49) were removed from Annex I by Amending Regulation (EU) 2025/2650.
  • What matters is the customs tariff code, not the product description. Two outwardly similar articles can be classified differently.
  • An operator places a product on the market for the first time or exports it. Downstream businesses and traders pass on what is already on the market – with different obligations.
  • Size matters: downstream businesses and traders only have to register if they are not SMEs (Art. 5(2)).

Check now whether you are affected

The relevance check uses your details on products and activity for a first indication. It does not replace a binding legal assessment.

From when does it apply to me?

The regulation entered into force on 29 June 2023; the date of application has been postponed twice. Which deadline applies depends on size and role.

  • Operators as well as downstream operators and traders – unless the exception below applies
  • Micro and small enterprises acting as operators (importers, producers) that were already established as such on 31 December 2024 (Art. 38(3))
  • The same companies, for products already covered by the EU Timber Regulation (EUTR)

The exemption in Art. 38(3) refers, by its wording, only to operators. It is therefore not open to small downstream businesses and traders – for them we work with 30 December 2026. This distinction is often overlooked and decides whether you have six more months or not.

What do I have to do?

Obligations differ by role. The full scope applies to operators.

01

Register

The due diligence statement is submitted by whoever places a product on the market for the first time or exports it. Registration in the EU information system is required for this.

02

Exercise due diligence

Collect origin information – including geolocation of the plots of production –, assess risk and mitigate it where it is not negligible.

03

Pass on the reference number

The reference number must be passed on to direct commercial customers. Only the first downstream operator has to collect them – further down the chain this obligation no longer applies.

04

Keep records for five years

Documents and due diligence statements must be kept for five years and presented to the authorities on request. In Austria the competent authority is the Bundesamt für Wald.

Document check in the EUDR agent: the sequence from text recognition through classification and Article 9 fields to gap report and follow-up request, with the upload area below.
Document check in the EUDR agent

Relief for small primary producers

For small and micro primary producers the amending regulation introduces a one-off, simplified declaration. Whether you fall under it depends on size and activity.

What Step7 takes on

We start by classifying your products and activities and build the path to implementation from there: which data is needed, who supplies it, who decides, and how the documentation becomes auditable.

  • Record products and activities, establish exposure and deadline
  • Clarify data requirements, supplier information and responsibilities
  • Set up process and documentation, prepare the due diligence statement
Typical outcome Typical outcome: a transparent process, a list of open data questions and a concrete implementation plan.

Request a first conversation

Other EU requirements

CBAM, CSRD, NIS2, supply chain due diligence: if you want to know which of these will affect you and in what order, we will take it up in a conversation. This register grows with the requirements we actually support – we do not list anything here that we do not implement.

Request EUDR consulting

Official sources

Checked on 21 October 2026 against Regulation (EU) 2023/1115 as amended by Regulation (EU) 2025/2650 and the information published by the competent authorities. Guidance, not legal advice.

This page reflects the legal situation we have verified. Scope and obligations depend on your business model; binding information is provided by the competent authorities.