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The importer is the operator.
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EU Deforestation Regulation · UK suppliers
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
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)).
| Change to Annex I | Products | From |
|---|---|---|
| Removed | Cattle leather, re-treaded tyres (the tread stays), conveyor belts and other vulcanised rubber articles, soybeans for sowing, aircraft and vehicle seats | 18 September 2026 |
| Removed earlier | Printed books, newspapers and other printing-industry products | Regulation (EU) 2025/2650 |
| Added | Soluble coffee, palm-oil derivatives such as soap, frozen cattle tongues | 30 December 2027 |
| Unchanged examples | New tyres, soya meal and oil, wooden furniture, cocoa and chocolate | Application 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
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).
The importer is the operator.
You supply geolocation and production dates.You are an operator, even from outside the EU.
The first EU business that sells on is an operator too.You are an operator there from 30 December 2026.
Northern Ireland to Great Britain needs nothing.One supplier
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.
The Dutch retailer, which imports them, so it is the operator (Commission).
No: selling to an EU buyer who imports does not count as placing on the EU market (Commission).
The geolocation of the forest plots where the timber was harvested, and the time of harvest (Art 9(1)(d)).
Yes: timber grown in the UK, a low-risk country, allows the retailer simplified due diligence (IR 2025/1093).
30 December 2026, because wooden furniture was under the EU Timber Regulation (Art 38(3)).
What is at stake
Member states set penalties, but for a company the maximum fine must be at least 4% of EU-wide turnover.
| Measure | What the Regulation requires | Article |
|---|---|---|
| Fines | A maximum of at least 4% of total annual EU-wide turnover for a legal person, raised where needed to exceed the gain | Art 25(2)(a) |
| Confiscation | Of the products and of the revenues gained | Art 25(2)(b)–(c) |
| Exclusion | From public procurement and public funding for up to 12 months | Art 25(2)(d) |
| Market ban | A temporary prohibition on placing products on the market, for serious or repeated breaches | Art 25(2)(e) |
| Checks | Each year at least 1% of operators sourcing from low-risk countries, 3% standard risk, 9% high risk | Art 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
Produced on land not deforested after 31 December 2020, measured against fixed definitions of forest.
The test
The test
The test
Low risk
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).
Your role
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
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).
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 Ireland
Northern Ireland
Northern Ireland
Order of work
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.
Use the 18 September 2026 consolidation, not the 2023 list.
Supplier to an importer, operator, or first placer in Northern Ireland.
Geolocation to six decimal places, and the production dates.
UK-grown is low risk; imported commodities follow their own country.
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.
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 regime
The UK regime
Frequently asked
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.
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.
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.
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.
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.
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.
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.
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.
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
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
Application from 30 December 2026; micro and small operators from 30 June 2027, except EU Timber Regulation products.
Operators, the due diligence statement, geolocation, Article 7 and penalties.
The second postponement, downstream operators and micro or small primary operators.
Annex I rewritten, in force 18 September 2026; added products apply from 30 December 2027.
Country benchmarking: the UK is low risk.
Information System rules; statements by non-EU operators attributed from 15 October 2026.
No further amendment proposed; dated 4 May 2026.
The dates by operator size, and the Information System launched on 4 December 2024.
Selling to an EU-based buyer who imports does not count as placing on the EU market.
Leather, re-treaded tyres, soybeans for sowing and vehicle seats removed; soluble coffee added.
EUDR applies in Northern Ireland, not Great Britain; OPSS and DAERA as competent authorities.
Phased application in Northern Ireland from 30 December 2026.
The UK is classed as low risk; the GB regime is planned for 2027.
Union acts listed in Annex 2 are read “as amended or replaced”.
The UK’s own forest risk commodity framework; no regulations made.
The earlier, superseded UK proposal.
Continue reading
The Environment Act 2021 framework and the GB plan for 2027.
Answering customers’ supply-chain questions.
When EU sustainability reporting reaches a UK group.
The UK duties that are law.