Does the EUDR apply to products made in the EU, for example in Spain?

Yes. It applies to everything placed on the EU market, including what is produced here. The EU is classified as low risk, so European producers carry out simplified due diligence, but they still need the geolocation.

What happens to the EUTR for timber?

The EUDR repeals it. Products that were under the EUTR move to the EUDR from 30 December 2026 for all companies, micro and small enterprises included.

Does an SME that only resells have to do anything?

As an SME trader it does not submit DDSs and does not have to register. It does have to collect the reference numbers of the DDSs for the products it buys and sells, and keep them for 5 years.

What is the EUDR and who does it apply to

The EUDR is Regulation (EU) 2023/1115. It bans selling in the EU, or exporting from it, coffee, cocoa, soya, palm oil, rubber, wood and cattle (and the derived products in its Annex I) if they come from land deforested after 31 December 2020 or were not produced legally. Whoever places them on the market first has to prove this with a due diligence statement (DDS) in TRACES.

What it prohibits

Article 3 sets three conditions at once. A product listed in Annex I can only be placed on the EU market, or exported, if it meets all three:

Deforestation-free: the commodity was produced on land that has not been deforested after 31 December 2020. For wood, also without forest degradation after that date.
Legal: produced in line with the laws of the country of production (land use, environment, labour, human rights and tax, among others; Art. 2(40)).
Covered by a due diligence statement submitted to the EU information system, which sits inside TRACES NT.

The cut-off date does not move with the delays. What has been postponed is the date from which the Regulation applies. 31 December 2020 is still the reference for deciding whether a plot of land qualifies.

Which products it covers

Seven commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood. But the real scope is set by Annex I, which works by Combined Nomenclature (CN) codes. A product is in scope if its code is in the annex, not because it "contains" one of those commodities.

Two examples. A piece of wooden furniture under heading 9403 is in scope. A bamboo one is not, because bamboo does not count as wood. A chocolate bar (1806) is in scope. A chocolate biscuit (1905) is not, although the chocolate the manufacturer buys is. If you are unsure about a code, the CN code checker tells you whether it is in Annex I.

The annex has changed twice. Regulation (EU) 2025/2650 removed the printed products of Chapter 49. Delegated Regulation (EU) 2026/2102, in force since 18 September 2026, removed cattle leather and hides, several vulcanised rubber articles and the casings of retreaded tyres. It also added soluble coffee, more palm derivatives and frozen cattle tongues, which apply from 30 December 2027.

Who it applies to and what each party has to do

The December 2025 reform made it clear that only whoever places the product on the market first submits the DDS. The rest of the chain keeps reference numbers. These are the roles:

Operator: whoever imports the product into the EU, produces it in the EU and places it on the market for the first time, or exports it. The operator carries out full due diligence and submits the DDS before customs clearance or export.
Downstream operator: whoever processes or resells a product that already has a DDS (the roaster buying green coffee from a Spanish importer, the furniture factory buying boards in Valencia). A downstream operator does not submit a DDS. It collects the reference numbers of the upstream DDSs and keeps them for 5 years.
Trader: whoever sells a product that is already on the market without processing it. Same obligations as a downstream operator.
Registration: downstream operators and traders that are not SMEs have to register in the information system even though they do not submit DDSs.

If your supplier is outside the EU and sells you a product that someone else has already cleared, read Article 7. When the party placing the product on the market is not established in the EU, the first person established in the EU that makes it available is treated as the operator. And if you do not want to submit DDSs yourself, a third party can do it as your authorised representative.

What an operator has to do

Due diligence under Article 8 has three steps. The DDS is the summary you submit at the end:

Collect information (Art. 9): product description and code, quantity, country of production, geolocation of every plot of land, date or period of production, suppliers and customers, and evidence that there is no deforestation and that production is legal.
Assess the risk (Art. 10): with that information, decide whether the risk that the product does not comply is none or negligible.
Mitigate the risk (Art. 11): if it is not, ask for more data, run audits or change supplier until it is. If you cannot get there, the product cannot be placed on the market.

You keep all that information for 5 years from the date the product was placed on the market or exported (Art. 9). The due diligence system is reviewed at least once a year (Art. 12).

Low, standard and high risk countries

The Commission classifies countries by deforestation risk (Art. 29). The current list is in Implementing Regulation (EU) 2025/1093. Belarus, North Korea, Myanmar and Russia are high risk. EU Member States, the United States, Canada and China, among many others, are low risk. Countries on neither list, such as Brazil, Indonesia or Côte d'Ivoire, are standard risk.

If everything you buy comes from low-risk countries, you apply the simplified due diligence of Article 13. You do not have to assess or mitigate the risk, but you still collect the Article 9 information, geolocation included. The risk level also changes how intense the checks are: every year the authorities check at least 3% of operators for each commodity, and 9% for high-risk countries (Art. 16).

From when

30 December 2026 for large and medium-sized companies, for all downstream operators and traders, and for micro and small enterprises with wood products that were already under the EUTR. 30 June 2027 for all other micro and small enterprises. The details are in the guide to EUDR deadlines.

Where to start

If you import any of these products, this is the order that works:

List the CN codes you import and check which ones are in Annex I.
For each one, decide your role: operator, downstream operator or trader.
Ask your suppliers for the list of producers and the geolocation for a real shipment. That will show you who can provide it and who cannot.
Register your company in TRACES with EU Login and test a DDS from start to finish.

Frequently asked questions

Does the EUDR apply to products made in the EU, for example in Spain?: Yes. It applies to everything placed on the EU market, including what is produced here. The EU is classified as low risk, so European producers carry out simplified due diligence, but they still need the geolocation.
What happens to the EUTR for timber?: The EUDR repeals it. Products that were under the EUTR move to the EUDR from 30 December 2026 for all companies, micro and small enterprises included.
Does an SME that only resells have to do anything?: As an SME trader it does not submit DDSs and does not have to register. It does have to collect the reference numbers of the DDSs for the products it buys and sells, and keep them for 5 years.