European UnionDelayed
Corporate Sustainability Due Diligence Directive
Scope is now 5,000 employees and EUR 1.5 billion turnover, with fines capped at 3 percent; the guidelines consultation closed on 24 July 2026.
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Plot-level proof that seven commodity groups entering the EU are deforestation-free and legally produced, required from 30 December 2026.
Leather left the scope on 18 September 2026, when Delegated Regulation (EU) 2026/2102 entered into force.
In plain language
The EUDR requires companies placing relevant commodities on the EU market to prove, with plot-level geolocation data, that products are deforestation-free after the 2020 cut-off and produced in compliance with the laws of the country of production. After two postponements, obligations apply to large and medium operators from 30 December 2026, together with micro and small operators already covered by the old Timber Regulation. All other micro and small operators follow on 30 June 2027.
The revision of Annex I is now law. The Commission adopted the delegated act on 13 July 2026, and it was published as Delegated Regulation (EU) 2026/2102 on 17 September 2026, entering into force the following day. The removals took effect immediately, so cattle hides, skins and leather, vulcanised rubber belts and articles, aircraft and motor vehicle seats, soybeans for sowing and retreaded tyres are no longer covered. Soluble coffee, certain palm oil derivatives, frozen cattle tongues and palm-based soaps were added, and they come into scope on 30 December 2027.
For producer countries the regulation has already reshaped procurement. Buyers are demanding polygon mapping from farm level upwards, and smallholders without digital land records face exclusion risk unless supported. The country benchmarking system determines the intensity of checks that shipments face at the border. Tanneries and leather exporters are now outside the regime altogether, although the cattle and beef those hides come from remain covered.
For suppliers
A latitude and longitude point for each plot up to four hectares, and a polygon for anything larger, in decimal degrees to at least six decimal places. The EU information system accepts GeoJSON only, so a spreadsheet of village names will be rejected.
Proof that the land was not deforested after 31 December 2020. In practice this means satellite history or land records tied to the same coordinates you supplied, not a general statement about the region.
Documents covering land use rights, environmental and forest law, labour rights, third party rights, and trade and customs rules in the country of production. Legality is assessed against the producing country law, not EU law.
The first operator placing goods on the EU market submits the due diligence statement in the TRACES system. A supplier outside the EU does not file, so the data you hand over becomes somebody else's legal declaration.
Since the December 2025 amendment, downstream buyers no longer file their own statements and simply keep the reference number of the first one. Nothing further down the chain re-checks your data, so an error surfaces at the border rather than in the paperwork.
Only Belarus, North Korea, Myanmar and Russia are classed high risk. Most producing countries are standard risk, where authorities must check at least 3 percent of operators, against 9 percent for high risk and 1 percent for low risk.
Large and medium operators, and downstream operators of every size, are covered from 30 December 2026. Micro and small operators follow on 30 June 2027, except in the timber sector, where they are covered from December 2026.
Cattle hides, skins and leather left the scope on 18 September 2026. Cattle and beef remain covered, so a tannery sits outside the regulation while the herd behind it does not.
Obligations
Every relevant shipment requires a due diligence statement referencing plot-level coordinates for the production location.
Products must not be produced on land deforested after 31 December 2020, regardless of local legality.
Production must comply with the producing country laws on land use, labour, human rights and tax.
Timeline
Regulation entered into force.
First postponement moved application back by twelve months following implementation concerns.
Country benchmarking classifications published, sorting producer countries into risk tiers.
Second postponement published in the Official Journal one week before application, moving large operators to 30 December 2026 and micro and small enterprises to 30 June 2027.
Commission published its simplification review of the regulation, with revised guidance, FAQs and a draft change to the product scope.
Commission adopted a delegated act removing leather and several other products from Annex I and adding soluble coffee, palm oil derivatives and frozen cattle tongues, plus an implementing act simplifying declarations for micro and small primary operators.
Delegated Regulation (EU) 2026/2102 published in the Official Journal after scrutiny ended without objection; the removals from Annex I took effect on 18 September 2026.
Obligations apply to large and medium operators and traders, and to micro and small operators already covered by the Timber Regulation.
Obligations apply to all other micro and small enterprises.
Products newly added by the delegated act come into scope.
Changelog
Leather removal confirmed as law: Delegated Regulation (EU) 2026/2102 was published on 17 September 2026 and took effect the next day.
Added the July 2026 delegated act removing leather from scope, corrected application dates to include medium operators, and replaced a summary paragraph that still gave the superseded 2025 dates.
SME application date confirmed; entry updated with benchmarking country classifications.
Exposed export value at full application, across the ten tracked origins · Figures come from UN Comtrade. For each country we use what its buyer markets reported importing, rather than what the country itself reported exporting, because several tracked countries report to Comtrade late or not at all. Every share is measured against that country's exports to the nine regulated markets this index tracks, not against its total exports to the world, because no reliable world total exists for countries that under-report. European Union figures add up all twenty seven member states. The European product breakdown by chapter is estimated from the four largest importers, Germany, France, the Netherlands and Italy, and scaled up to the full twenty seven member total, so it captures which products dominate without understating any single one. · methodology
Same jurisdiction
Scope is now 5,000 employees and EUR 1.5 billion turnover, with fines capped at 3 percent; the guidelines consultation closed on 24 July 2026.
Read →Revised reporting standards published on 21 September 2026 and in force from 10 November, with the value chain cap now final.
Read →Commission adopted its implementation guidelines on 26 June 2026 and launched the Single Portal and risk database on 30 June.
Read →