The EU Deforestation Regulation (EUDR) has been postponed twice. A third delay now looks unlikely: in its 5 October analysis, FoodNavigator judged on-time implementation more likely than another postponement. The European Commission is already training companies to file in its Information System.
From 30 December 2026, products made from cattle, cocoa, coffee, palm oil, rubber, soy and wood can only be placed on the EU market if a due diligence statement (DDS) covers them. For non-EU exporters and e-commerce sellers who import in their own name, one detail is easy to miss: the EU’s system will not validate your operator account without an EU EORI number.
This guide explains what changes, what a DDS contains, how it reaches customs, and what to do before your next shipment clears.
What changes on 30 December 2026
The EUDR’s main obligations apply from 30 December 2026. That date covers large and medium operators and traders, all downstream operators and traders, and micro and small operators selling timber products already covered by the old EU Timber Regulation. Other micro and small operators follow on 30 June 2027.
From then on, an in-scope product may be placed on the EU market or exported only if it is:
- deforestation-free, meaning produced on land not deforested after 31 December 2020;
- legal, meaning produced in line with the relevant laws of the country of production;
- covered by a due diligence statement filed in the EU Information System.
The rules were simplified in December 2025. Only the operator that first places a product on the EU market, or exports it, now files the DDS. Businesses further down the chain keep and pass on its reference number instead.
The product list changed too. Since 18 September 2026, hides, skins and leather, retreaded tyres, some vulcanised rubber articles, soya beans for sowing, and vehicle and aircraft seats are out of scope. Soluble coffee, certain palm-oil derivatives and frozen cattle tongues join on 30 December 2027.
Don’t plan around another reprieve. The Commission’s May 2026 review kept the timetable, and the Commission has kept stressing that date since.
What goes into an EUDR due diligence statement
A DDS is the operator’s formal declaration that it has done due diligence and found no risk, or only a negligible one. You create it in the EU Information System, which runs on the Commission’s TRACES platform. Each statement carries:
- Operator details: name, address and, for goods entering or leaving the EU market, the EORI number.
- Product details: HS code, description, trade name and quantity; for wood, the common and scientific names of the species.
- Country of production and the geolocation of every plot where the commodity was grown or raised. Plots over four hectares need a polygon rather than a single point, except for cattle. You can draw areas on a map, enter coordinates or upload a GeoJSON file.
- Reference numbers of earlier statements when your product is made from inputs already covered by a DDS.
- A signed confirmation that due diligence was carried out and no or only negligible risk was found.
Behind the statement sits the due diligence itself: collecting evidence, assessing the risk of deforestation and illegality, and mitigating any risk found. Sourcing only from countries the EU rates as low risk, such as the United States, China or the UK, allows simplified due diligence. You still collect the information, but you can skip the risk assessment and mitigation.
Once the statement is accepted, the system returns a reference number and a verification number. Keep both, with the supporting evidence, for five years.
How the DDS reference reaches EU customs
At the border, the EUDR becomes a customs matter. When in-scope goods are released for free circulation or exported, the DDS reference must be available to customs on the declaration. So the statement has to be submitted before the customs declaration is lodged, not after.
The link runs through TARIC document codes on the declaration:
- C716 tells customs the declarant holds a due diligence statement. The DDS reference number follows it.
- The code goes in data element 12 03 002 000 and the reference number in 12 03 001 000.
- Other codes, updated by the Commission in September 2026, cover simplified declarations from small producers, re-imports, samples, packaging and used goods.
Customs and the national competent authorities use the Information System to check statements. Without a valid reference, expect your goods to be held at the border.
In practice your forwarder or customs broker files the declaration, so they need the DDS reference and verification numbers before the goods arrive. Agree a simple handover, such as sending the references with the commercial invoice for every shipment.
The date that counts is the customs release date, not the shipping date. Goods loaded in November but cleared after 30 December 2026 need a DDS reference too.
Why non-EU companies need an EU EORI number first
If you import into the EU in your own name, for example when you ship DDP or fulfil online orders, you are the operator. That holds for direct sales to consumers too: an EU consumer is never the operator, even when named as importer on the customs declaration.
As the operator, you register in the Information System and file the DDS. Here the EORI matters twice:
- Account validation. The system validates an operator account from outside the EU only once an EORI issued by an EU Member State (or by the UK for Northern Ireland) is added under Operator Identifiers. You then ask the Commission’s SANTE support team to validate it, copying the EUDR competent authority of the country that issued your EORI.
- Customs identity. Your EORI goes on every import declaration and, for goods entering the EU, on the DDS itself.
An EORI comes from one customs authority only. Without an EU establishment, you apply in the Member State where you plan to lodge your first customs declaration. The number is then valid across the EU, and the Information System treats the issuing country as your associated Member State.
If your EU customer imports instead, they become the operator and file the DDS. You still have work to do: they will need plot geolocation, legality evidence and product data from you. And if you import but an EU business resells the goods, Article 7 deems that business an operator too, so agree up front who files what.
Checklist for exporters, e-commerce sellers and forwarders
Work through these steps before your first shipment that will clear after 30 December 2026:
- Check your products. Match each CN code against the updated Annex I list, including the September 2026 changes.
- Get an EU EORI number in the Member State where you will lodge your first import declaration.
- Register in the Information System as “EUDR operator”, add your EORI under Operator Identifiers and request validation. Practise on the acceptance server first: it needs its own registration, and its submissions have no legal effect.
- Collect the evidence from suppliers: plot geolocation, production dates, legality documents and supplier contact details.
- Submit the DDS before the customs declaration is lodged, and store the reference and verification numbers.
- Brief your forwarder or broker so every declaration for in-scope goods carries code C716 and the right reference.
- Join a Commission training session. Sessions on submitting due diligence statements run on 3, 10, 17 and 24 November 2026 at 14:00 CET.
E-commerce sellers: the EUDR covers online sales, but low-value parcels often travel on a reduced customs data set. Ask your carrier or platform now how they will pass on your DDS reference.
Need an EU EORI number for EUDR? Your operator account can’t be validated without one. Apply for an EORI number at eorinumber.eu and have it in place before you register and file your first due diligence statement.
EUDR FAQs
Which Member State should issue my EORI number?
If your business has no establishment in the EU, apply in the Member State where you plan to lodge your first customs declaration. You can hold only one valid EORI at a time, and it works across the EU. For the EUDR, that country becomes the associated Member State whose competent authority is copied when your account is validated.
Who files the DDS when I ship DDP?
You do. As importer of record, you place the goods on the EU market, so you are the operator. If an EU business then resells them, it is also deemed an operator under Article 7, so agree with your customer who submits what.
Do I need a DDS if my EU customer imports the goods?
No, your customer files it as the operator. Expect them to ask for plot geolocation, production dates and legality evidence, because their statement depends on your data.
Does the EUDR apply to goods sold online to EU consumers?
Yes. It covers distance sales made in the course of a commercial activity, including direct-to-consumer sales. Goods for private, non-commercial use are the exception.
Is leather still covered?
No. Since 18 September 2026, cattle hides, skins and leather are outside the EUDR. Live cattle and beef are still covered.
What happens if I get it wrong?
Each Member State sets its own penalties, but the EUDR fixes a floor. For companies, the maximum fine must be at least 4% of total annual EU-wide turnover. Authorities can also confiscate goods and revenue, exclude firms from public contracts for up to 12 months, and temporarily ban sales.
When do micro and small companies have to comply?
Most from 30 June 2027. Micro and small operators selling timber products already covered by the EU Timber Regulation must comply from 30 December 2026.
Get your EORI number before 30 December
Two months is not long when supplier data, system registration and broker briefings all hang on one identifier. If you plan to import EUDR goods into the EU in your own name, start with the EORI.
Apply for an EORI number at eorinumber.eu so your number is active before you register in the Information System and file your first due diligence statement.
This article is general information as of 28 October 2026, not legal advice. Check the official sources below before acting.
Sources
- European Commission, Access2Markets: Delay until December 2026 and other developments in the implementation of the EUDR, 28 January 2026
- European Commission, DG Environment: Commission updates product scope and digital tools to support implementation of the EUDR, 13 July 2026
- European Commission: The Information System of the EU Deforestation Regulation
- TRACES help: Create an account in EUDR Platform
- European Commission newsroom: Updated TARIC document for EUDR published, 25 September 2026
- European Commission, DG TAXUD: TARIC data for Regulation (EU) 2023/1115, 30 September 2024
- European Commission: Economic Operators Registration and Identification number (EORI)
- Regulation (EU) 2023/1115 on deforestation-free products, EUR-Lex
- FoodNavigator: The EUDR is on the horizon – could it change again?, 5 October 2026
- Reed Smith: EUDR simplification and clarification on scope for online sales, 11 May 2026