EU Deforestation Regulation (EUDR)

What does the EUDR require?

Three conditions apply to every relevant product (Article 3). It must be deforestation-free, meaning the commodity was produced on land not deforested after the cut-off date of 31 December 2020. It must be produced in line with the relevant legislation of the country of production. And it must be covered by a due diligence statement or, for micro or small primary operators, a simplified declaration.

Due diligence has three steps: collecting information, including the geolocation of every plot of land; risk assessment; and risk mitigation until the risk is negligible.

What changed with the 2025 amendment?

Regulation (EU) 2025/2650 moved the filing obligation to the first actor placing a product on the EU market or exporting it (the operator). Downstream operators and traders no longer submit their own statements; the first ones in the chain collect the reference numbers they receive. It also created a one-time simplified declaration for micro or small primary operators in low-risk countries. Delegated Regulation (EU) 2026/2102, published on 17 September 2026 and in force since 18 September 2026, then revised the product list in Annex I.

Why does it matter at the first mile?

The evidence the EUDR asks for is created at origin: plot boundaries, farmer identities, harvest dates and land rights. Most of it concerns smallholders who sell through cooperatives and intermediaries, which is where data is most often missing or inconsistent.

Common pitfalls

• Treating the EUDR as a paperwork exercise at import, when the data has to exist at the farm.
• Relying on outdated guidance. Parts of the 2024 FAQ were removed after the 2025 amendment.
• Mixing verified and unverified volumes without controls.

Farmer1st provides the first-mile data layer that feeds EUDR compliance, from plot mapping to TRACES-ready statements. See also our EUDR guide.