The EU Deforestation Regulation binds large and medium operators from 30 December 2026. The Commission confirmed in May 2026 that there will be no further delay.
Most of the market treated the December 2025 postponement as permission to stop. Four months out, a lot of the build has not started.
Who it binds
- Large and medium operators and traders, and downstream operators, from 30 December 2026.
- Micro and small enterprises from 30 June 2027 — but only where established as such by 31 December 2024, and legacy EUTR timber products stay at 30 December 2026 regardless of size.
- Commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood, and products derived from them.
What it actually demands
- A due diligence statement filed by the operator who first places the product on the EU market.
- Downstream operators and traders collect and retain the DDS reference number / declaration identifier rather than filing their own — and, per the May 2026 review, are not required to actively request them.
- Geolocation data — plot polygons — held against the supplier and material combination.
- Supplier and recipient data retained five years.
- Registration in the EUDR Information System, relaunched June 2026.
The reference number is the whole mechanism, and it is a field that does not exist in a standard ERP. It has to be captured at goods receipt, held against the lot, and propagated to the sales line of anything made from it. Retro-fitting that after go-live means re-tracing lots you have already shipped.
What it means for the estate
This is lot traceability plus a document reference, not a reporting exercise. The DDS reference has to survive the transformation from inbound material to outbound finished good, which means it lives on the lot, not the purchase order header.
Geolocation is master data against the supplier-material pair. It is stable, it is bulk-loadable, and it is the cheapest part — which is why it is usually the only part that gets done.
The simplification agreed in May 2026 materially reduces the build for downstream operators. Confirm which side of 'first placing on the market' you are on before scoping anything: it is the difference between filing and filing nothing.
Caveat
Proposed scope changes — removing cattle hides and retreaded tyres, adding soluble coffee and palm oil derivatives — were consulted on to 1 June 2026 and are not yet law.
Primary sources
Related
Run the exposure check — three minutes, free, and it will tell you which of the other 11 dates catch you as well and in what order they have to be done. Sequencing is most of the cost on these programmes.