EUDR update: Enforcement delayed to December 2026, April review pending

If you import timber, soy, coffee, cocoa, palm oil, rubber, or cattle products into the EU, you should have started preparing. EUDR enforcement is confirmed for 30 December 2026 for large and medium operators (30 June 2027 for SMEs). The European Commission publishes a simplification review at the end of April 2026.

What is EUDR?

The EU Deforestation Regulation aims to reduce greenhouse gas emissions and biodiversity loss by boosting the consumption of deforestation-free products and by reducing the EU's impact on global deforestation and forest degradation. The regulation will cut carbon emissions linked to EU consumption and production of covered commodities by at least 32 million tonnes per year.

Who is directly affected?

Companies that import or export the following commodities (and certain derived products) into the EU: cattle and leather products, wood and wood products (e.g., furniture), cocoa (e.g., chocolate), soy, palm oil, coffee, and rubber (e.g., tyres).

Scope update: Printed products (e.g., books, newspapers, printed pictures) have been removed from the regulation's scope following the simplification update adopted in December 2025.

• See full scope (Annex I)
• EU Deforestation Regulation overview

How Flexport helps

Flexport digitises 7 of 12 required data points across shipment lifecycle. We can help gather and structure data we see in-platform; customers must still obtain batch-level and plot geolocation data from manufacturers and file the DDS.

Flexport does not file the DDS and cannot source batch/plot geolocation data from manufacturers on your behalf.

For questions or to discuss EUDR preparation, contact the EMEA Customs team.

What importers need to do

1. Map your supply chain to identify in-scope commodities Determine which products you import fall under EUDR (cattle, cocoa, coffee, oil palm, rubber, soya, wood). SMEs have limited obligations — only retain and pass on due diligence information.
2. Trace products to plot of land Products must be traceable to the production plot, including precise geolocation coordinates for each plot that supplied the commodity. This is the most challenging requirement for most importers.
3. Conduct risk assessment Assess and mitigate risks that products contributed to deforestation or forest degradation, including verification of legality in the country of origin.
4. Submit Due Diligence Statement (DDS) The DDS reference must be included in import declarations by your customs broker for customs release. Start aligning internal systems now to store and transmit DDS references with customs data.

Best practice: Start mapping suppliers to plots now. Collect geolocations and documentation at batch/lot level.

What to look out for: April 2026 simplification review

The European Commission will publish a simplification review report on 30 April 2026. The review will evaluate administrative burden (especially for SMEs) and may be accompanied by a legislative proposal.

The big question of the simplification review: will there be an additional "no-risk" category?

The April simplification review may introduce a "no-risk" category that exempts certain countries from traceability requirements. The World Resources Institute warns this could enable deforestation laundering, allowing high-risk commodities to be routed through no-risk countries and exported to the EU without origin verification. In the current EUDR package, a low-risk category already exists for EU Member States and the United States with reduced compliance requirements.

Timeline:

Penalties for non-compliance:

• Fines up to 4% of total annual union-wide turnover
• Suspension of market access and seizure of goods
• Reputational damage and release delays at custom

Resource links:

• EU Commission EUDR page
• WRI: No-risk category would weaken EUDR
• Flexport EUDR knowledge base
• EUDR Update: What It Means for You and How Flexport Can Help
• EU Deforestation Regulation (EUDR): A Guide for Importers