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EU Deforestation Regulation · UK suppliers

The EUDR for UK businesses that supply the EU

The EU Deforestation Regulation applies from 30 December 2026 to cattle, cocoa, coffee, oil palm, rubber, soya and wood products placed on the EU market.

A UK business that sells to an EU importer is not the operator, but its customer will need the geolocation of the land the commodity came from.

A UK business that imports into the EU itself, or is first to sell into Northern Ireland, is an operator with duties of its own.

What it covers

What is the EUDR?

An EU rule that products of seven commodities must be deforestation-free, legal where produced and covered by a due diligence statement.

Regulation (EU) 2023/1115 covers products in its Annex I made with cattle, cocoa, coffee, oil palm, rubber, soya or wood (Art 1(1)).

Sources: Delegated Regulation (EU) 2026/2102 · DG ENV, 13 July 2026 · Regulation (EU) 2025/2650 Art 1(26)
Change to Annex IProductsFrom
RemovedCattle leather, re-treaded tyres (the tread stays), conveyor belts and other vulcanised rubber articles, soybeans for sowing, aircraft and vehicle seats18 September 2026
Removed earlierPrinted books, newspapers and other printing-industry productsRegulation (EU) 2025/2650
AddedSoluble coffee, palm-oil derivatives such as soap, frozen cattle tongues30 December 2027
Unchanged examplesNew tyres, soya meal and oil, wooden furniture, cocoa and chocolateApplication dates

Lists that still show leather or books are the 2023 text, and the current one is the consolidation of 18 September 2026 (EUR-Lex).

UK businesses

Does the EUDR apply to UK businesses?

It depends on who places the goods on the market: the operator files, a supplier supplies data.

The operator is whoever first places a product on the EU market or exports it, and only the operator files a due diligence statement (Arts 2(15), 4(2)).

Where a business outside the EU places goods on the market, the first business established in the EU to make them available is also deemed an operator (Art 7).

The Commission puts it plainly: selling to an EU-based buyer who will import the goods “does not count as placing directly on the EU market” (Commission).

A UK business with in-scope goods

Sells to an EU importer

The importer is the operator.

You supply geolocation and production dates.

Imports into the EU itself

You are an operator, even from outside the EU.

The first EU business that sells on is an operator too.

First to sell into Northern Ireland

You are an operator there from 30 December 2026.

Northern Ireland to Great Britain needs nothing.

Commission: roles · Art 7 · GOV.UK

One supplier

What does this mean for one UK furniture maker?

A UK maker selling wooden chairs to a Dutch retailer that imports them files nothing, but must hand over where the timber grew.

It is an illustration, not a real company.

If the maker imported the chairs into the Netherlands itself, it would be the operator and file its own statement.

If the timber came from a standard-risk country, the retailer would need full due diligence, including a risk assessment.

  1. 1

    Who places the chairs on the EU market?

    The Dutch retailer, which imports them, so it is the operator (Commission).

  2. 2

    Is the UK maker an operator?

    No: selling to an EU buyer who imports does not count as placing on the EU market (Commission).

  3. 3

    What will the retailer ask for?

    The geolocation of the forest plots where the timber was harvested, and the time of harvest (Art 9(1)(d)).

  4. 4

    Does UK timber help?

    Yes: timber grown in the UK, a low-risk country, allows the retailer simplified due diligence (IR 2025/1093).

  5. 5

    From when?

    30 December 2026, because wooden furniture was under the EU Timber Regulation (Art 38(3)).

What is at stake

What happens if the rules are broken?

Member states set penalties, but for a company the maximum fine must be at least 4% of EU-wide turnover.

The base is EU-wide turnover, not global turnover. UK penalty rules for Northern Ireland were not located; competent authorities there are OPSS and DAERA (GOV.UK).
MeasureWhat the Regulation requiresArticle
FinesA maximum of at least 4% of total annual EU-wide turnover for a legal person, raised where needed to exceed the gainArt 25(2)(a)
ConfiscationOf the products and of the revenues gainedArt 25(2)(b)–(c)
ExclusionFrom public procurement and public funding for up to 12 monthsArt 25(2)(d)
Market banA temporary prohibition on placing products on the market, for serious or repeated breachesArt 25(2)(e)
ChecksEach year at least 1% of operators sourcing from low-risk countries, 3% standard risk, 9% high riskArt 16(8)–(10)

For a UK supplier the commercial risk comes first: an EU customer that cannot file a statement cannot place the goods.

Deforestation-free

What does deforestation-free mean?

Produced on land not deforested after 31 December 2020, measured against fixed definitions of forest.

The two limbs are separate: land legally cleared after 31 December 2020 still fails the deforestation-free test (Art 3).

Geolocation means coordinates to six decimal places, and polygons for plots of more than four hectares, except for cattle (Art 2(28)).

The testExplore

The test

Cut-off

No deforestation of the land after 31 December 2020; for wood, no forest degradation either.

Low risk

What does the UK’s low-risk status change?

Lighter due diligence for commodities produced in the UK, not an exemption, and nothing for goods grown elsewhere.

Only four countries are high risk, Belarus, North Korea, Myanmar and Russia; every unlisted country is standard risk (IR 2025/1093).

GOV.UK says the UK’s status lets operators use simplified requirements for goods produced in Great Britain and exported to the EU or moved to Northern Ireland (Defra).

  1. Simplified due diligence

    No risk assessment or mitigation

    For commodities produced in a low-risk country.
  2. Still required

    Information and a statement

    Geolocation is still collected, and a statement filed.
  3. Micro or small primary operator

    A one-off declaration

    For a small UK producer that places its own produce itself; a postal address may replace geolocation.
  4. Not covered

    Commodities grown elsewhere

    Low risk follows where the commodity was produced, not where the seller is.

IR 2025/1093 · Arts 2(15a), 13

Your role

What is your role under the EUDR?

Say where you are, what you do with the goods and what they are: your role, your start date and any lighter route follow.

The start dates follow Article 38: 30 December 2026 by default, 30 June 2027 for micro and small operators established as such by 31 December 2024, unless the product was under the EU Timber Regulation.

“Micro and small” uses the EU accounting directive’s size test, not the UK Companies Act one.

EUDR · what is your role?

Choose where you are and what you do with the goods.

Rules: Regulation (EU) 2023/1115 Arts 2, 4, 4a, 5, 7, 13, 37, 38 as amended by Regulation (EU) 2025/2650; Annex I as amended by Delegated Regulation (EU) 2026/2102; Implementing Regulation (EU) 2025/1093; GOV.UK Northern Ireland guidance.

A first reading of your role, not legal advice. Nothing you enter leaves your browser.

Deadlines

When does the EUDR apply?

30 December 2026, after two postponements, with later dates for micro and small operators and for new products.

Pages still giving 30 December 2025 are one postponement behind: Regulation (EU) 2025/2650 moved it a year (Reg 2025/2650).

  1. June 202301

    Regulation (EU) 2023/1115 enters into force

    The cut-off date for deforestation is fixed at 31 December 2020.

    Art 2(13)

  2. 4 December 202402

    Information System launched

    Where statements are filed.

    Commission

  3. 22 May 202503

    Country list adopted

    The UK is low risk; four countries are high risk.

    IR 2025/1093

  4. 19 December 202504

    Second postponement

    Regulation (EU) 2025/2650 moves application to 30 December 2026.

    Reg 2025/2650

  5. 4 May 202605

    Simplification review

    No further amendment proposed.

    COM(2026) 191

  6. 18 September 202606

    Annex I rewritten

    In force; additions from 30 December 2027.

    DR 2026/2102

  7. 30 December 202607

    Application, including Northern Ireland

    The EU Timber Regulation is repealed the same day.

    Arts 37, 38

  8. 30 June 202708

    Micro and small operators

    For products that were not under the EU Timber Regulation.

    Art 38(3)

  9. 30 December 202709

    Added products

    Soluble coffee, palm derivatives, frozen cattle tongues.

    DR 2026/2102

  10. 30 June 203010

    General review due

    Scope and other matters reviewed.

    Art 34(2)

Northern Ireland

Does the EUDR apply in Northern Ireland?

Yes, from 30 December 2026, in phases, replacing the EU Timber Regulation; it does not apply in Great Britain.

It applies under the Windsor Framework, which reads EU acts listed in its Annex 2, including the EU Timber Regulation, “as amended or replaced” (Article 13(3)).

The government confirmed the phased start in Northern Ireland on 23 June 2026 (GOV.UK).

Northern IrelandExplore

Northern Ireland

GB to NI

A GB business first placing goods on the NI market is an operator; movements carry the statement reference.

Order of work

What should a UK supplier do first?

Map which products are in Annex I, who places them on the market, and where each commodity was produced.

EU customers already reporting under the CSRD may ask for the same supply-chain data; see CSRD reporting for UK companies.

Supplier questionnaires that include deforestation questions are covered on ESG questionnaires.

  1. 1

    Check the current Annex I

    Use the 18 September 2026 consolidation, not the 2023 list.

  2. 2

    Fix your role for each customer

    Supplier to an importer, operator, or first placer in Northern Ireland.

  3. 3

    Trace origin to the plot

    Geolocation to six decimal places, and the production dates.

  4. 4

    Record the country risk

    UK-grown is low risk; imported commodities follow their own country.

  5. 5

    Agree the data hand-off

    What you send, when, and the statement reference that comes back.

Annex I · Art 9 · IR 2025/1093

A UK supplier rarely files under the EUDR, but its EU customers cannot file without the location of every plot it sources from.

  1. 30 December 2026

    The EUDR applies from this date, in the EU and Northern Ireland

    Micro and small operators of other products from 30 June 2027.
  2. Supplier, not operator

    A UK business selling to an EU importer files nothing itself

    But it must supply the geolocation.
  3. Low risk

    UK-grown commodities allow simplified due diligence

    Information and a statement are still required.
  4. 18 September 2026

    The product list changed

    Leather and vehicle seats out; soluble coffee in from 30 December 2027.
  5. At least 4%

    Maximum fines start at 4% of EU-wide turnover

    Member states set the penalties.

How is the EUDR different from the UK’s own deforestation rules?

The UK framework tests legality only, and none of it is in force yet.

The EUDR adds the deforestation-free test on top of legality, so a product can pass the UK test and fail the EU one.

The UK regime is explained on UK deforestation due diligence.

The UK regimeExplore

The UK regime

Schedule 17

An enabling framework on commodities produced on land used illegally; no regulations made.

Frequently asked

What else do UK businesses ask about the EUDR?

When does the EUDR apply?

From 30 December 2026 for large and medium operators, and for micro and small operators of products that were under the EU Timber Regulation.

Other micro and small operators, established as such by 31 December 2024, start on 30 June 2027.

Products newly added to Annex I, such as soluble coffee, apply from 30 December 2027.

Does the EUDR apply to UK companies?

Not to a UK business that sells to an EU customer who imports the goods: the importer is the operator.

A UK business becomes an operator if it imports into the EU itself, or if it is the first to place the goods on the Northern Ireland market.

Either way, EU customers will ask UK suppliers for the data their statements need.

Does the EUDR apply in Northern Ireland?

Yes, from 30 December 2026, in phases, replacing the EU Timber Regulation there. It does not apply in Great Britain.

A GB business that is first to place a product on the Northern Ireland market is an operator; moving goods from Northern Ireland to Great Britain carries no EUDR requirement.

Which products does the EUDR cover?

Products in Annex I that contain, were fed with or were made using cattle, cocoa, coffee, oil palm, rubber, soya or wood.

Delegated Regulation (EU) 2026/2102 removed cattle leather, re-treaded tyres, conveyor belts, soybeans for sowing and aircraft and vehicle seats, and added soluble coffee, palm-derived products such as soap and frozen cattle tongues from 30 December 2027.

What does low risk mean for UK products?

The UK is classed as low risk.

For commodities produced in a low-risk country, operators may use simplified due diligence: no risk assessment or mitigation, but they must still collect the information, including geolocation, and file a statement.

Low risk is about where the commodity was produced, not where the seller is.

What information will an EU customer ask a UK supplier for?

Above all the geolocation of every plot where the commodity was produced, to six decimal places, as polygons for plots over four hectares other than cattle, with the date or time range of production.

What are the penalties under the EUDR?

Each member state sets them, but for a company the maximum fine must be at least 4% of its total annual EU-wide turnover, alongside confiscation, exclusion from public procurement for up to 12 months and temporary market bans.

Is the EUDR being delayed again?

Not on current evidence.

The Commission’s simplification review of 4 May 2026 proposed no further amendment to the Regulation, and its follow-up was a product-list update and Information System rules.

How is the EUDR different from the UK’s own deforestation rules?

The EUDR requires products to be deforestation-free after 31 December 2020 and legal where produced.

The UK’s Schedule 17 framework tests legality only, and has no regulations made; the government plans GB legislation in 2027.

Sources

Where does each figure come from?

Every figure, date and status on this page traces to the instrument’s owner.

Secondary commentary is never the source for a number.

Checked against 19 sources fromEUR-LexEuropean CommissionEuropean Commission (Green Forum)European Commission (DG ENV)Defra (GOV.UK)GOV.UK
  1. EUR-Lex
    Regulation (EU) 2023/1115, consolidated text (18 September 2026), Articles 37 and 38 and Annex I

    Application from 30 December 2026; micro and small operators from 30 June 2027, except EU Timber Regulation products.

  2. EUR-Lex
    Regulation (EU) 2023/1115, consolidated text (December 2025), Articles 1–13, 25

    Operators, the due diligence statement, geolocation, Article 7 and penalties.

  3. EUR-Lex
    Regulation (EU) 2025/2650

    The second postponement, downstream operators and micro or small primary operators.

  4. EUR-Lex
    Commission Delegated Regulation (EU) 2026/2102

    Annex I rewritten, in force 18 September 2026; added products apply from 30 December 2027.

  5. EUR-Lex
    Commission Implementing Regulation (EU) 2025/1093

    Country benchmarking: the UK is low risk.

  6. EUR-Lex
    Commission Implementing Regulation (EU) 2026/1565

    Information System rules; statements by non-EU operators attributed from 15 October 2026.

  7. European Commission
    Simplification review on Regulation (EU) 2023/1115, COM(2026) 191

    No further amendment proposed; dated 4 May 2026.

  8. European Commission
    Simplification review: publication page
  9. European Commission
    Regulation on Deforestation-free Products

    The dates by operator size, and the Information System launched on 4 December 2024.

  10. European Commission (Green Forum)
    Understand roles and responsibilities under the EUDR

    Selling to an EU-based buyer who imports does not count as placing on the EU market.

  11. European Commission (Green Forum)
    Country classification list
  12. European Commission (DG ENV)
    Newsletter, 13 July 2026

    Leather, re-treaded tyres, soybeans for sowing and vehicle seats removed; soluble coffee added.

  13. European Commission
    Access2Markets: Delay until December 2026
  14. Defra (GOV.UK)
    Moving, exporting or placing deforestation-free products on the market in Northern Ireland

    EUDR applies in Northern Ireland, not Great Britain; OPSS and DAERA as competent authorities.

  15. GOV.UK
    Government steps up action to tackle illegal deforestation (23 June 2026)

    Phased application in Northern Ireland from 30 December 2026.

  16. Defra (GOV.UK)
    The UK’s approach to deforestation regulations

    The UK is classed as low risk; the GB regime is planned for 2027.

  17. EUR-Lex
    Withdrawal Agreement, Windsor Framework Article 13(3) and Annex 2

    Union acts listed in Annex 2 are read “as amended or replaced”.

  18. legislation.gov.uk
    Environment Act 2021, Schedule 17

    The UK’s own forest risk commodity framework; no regulations made.

  19. UK Parliament
    Written statement HCWS117 (12 December 2023)

    The earlier, superseded UK proposal.

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