EUDR applies on 30 December. There will be no further delay.

The EU Deforestation Regulation has been postponed twice, first to December 2025 and then to December 2026. Many businesses expected a third delay. In May the Commission published its simplification review and said plainly that there would be no postponement of the application date.

Who is caught, and when

• 30 December 2026: large and medium operators and traders, and micro and small operators in the timber sector.
• 30 June 2027: other micro and small operators.

The regulation covers cattle, cocoa, coffee, palm oil, rubber, soya and wood, and a long list of products made from them, such as chocolate, furniture and paper. The list keeps moving. Printed products such as books and newspapers were taken out in the December 2025 revision. A Commission delegated act of July 2026 then removed hides, skins and leather and some rubber articles, and adds soluble coffee and more palm oil derivatives from 30 December 2027. Check your product codes against the current list, not last year’s.

What has to be shown

Before covered goods are placed on the EU market or exported from it, the operator must be able to show three things:

1. Deforestation-free. The commodity was not produced on land deforested after 31 December 2020.
2. Legal. It was produced in line with the laws of the country of production.
3. Covered by a due diligence statement, backed by information that includes the geolocation of every plot of land where it was produced.

The 2026 changes cut the paperwork and narrowed the product list. They did not change these three tests.

Where supply chains break

Geolocation is the hard part. Cocoa, coffee and palm oil often pass through cooperatives, collectors and mills before an exporter sees them, and lots from many farms are mixed. A buyer who cannot get plot coordinates from the first link in the chain cannot complete the statement, however good the rest of its due diligence is.

UK businesses are not exempt in practice. A UK company exporting covered goods to the EU will be asked for the same evidence by its EU customer, who is the operator in law.

Where we come in

Meridian Intermediaries builds the evidence behind a supplier’s answer to its EU customer. We confirm which products are in scope, trace supply to plot and producer, and assemble legality and chain documents into one file. Each link is graded, so you and your customer can see what is proven.

Has an EU customer already asked for this evidence? The checklist at the end of this note sets out the 12 things they will ask a supplier for. Get the checklist →

What to check in the next twelve weeks

• Which of your products fall within the covered commodity and product codes.
• Whether you are an operator, a trader or a supplier to one, for each flow into the EU.
• Which suppliers can supply plot-level geolocation today, and which have only promised it.
• What you will do on 30 December with stock or contracts where the evidence is not complete.

Read next: Your EU customer files the EUDR statement. The evidence starts with you.