Dejan Jasnic · Co-founder & Compliance Lead, Trusty · 20+ years anti-fraud & compliance · ACFE Swiss Chapter Board
On 30 December 2026 the EUDR’s core obligations start to apply to operators, and to downstream operators and traders of any size; micro and small operators established as such by 31 December 2024, and natural persons, have until 30 June 2027, except for timber products listed in the Annex to the EU Timber Regulation. From that day, in-scope products can only be placed on the EU market or exported if they are deforestation-free, legally produced and covered by a due diligence statement. Customs checks the statement’s reference number, national authorities begin risk-based checks, and the old EU Timber Regulation is repealed. There is no grace period for EUDR enforcement.
30 December?
Supplier and plot data takes longest to prepare for EUDR enforcement. Collecting it in EUDR Passport is free, and suppliers answer in their own free account.
What switches on
Regulation (EU) 2025/2650 lists exactly what applies from 30 December 2026: Articles 3 to 13, 16 to 24, 26, 31 and 32 of the EUDR. In plain terms:
- The prohibition (Article 3). Relevant products may not be placed on the market, made available or exported unless they are deforestation-free, legal and covered by a due diligence statement.
- Due diligence (Articles 4 to 13). Operators collect information, assess risk, mitigate it and file statements; downstream operators and traders have their own, lighter duties.
- Checks and corrective measures (Articles 16 to 24). National competent authorities check companies and can order corrective action.
- Customs (Article 26). Customs authorities check in-scope goods at entry and exit.
- Records (Articles 4(3), 5(4), 9(1), 12(2) and 12(5)). Statements and evidence are kept for five years.
What changes at customs under EUDR enforcement
The customs declaration for an in-scope product must carry the reference number of its due diligence statement. In France, for example, the declaration uses document code C716 followed by the DDS reference number; code Y129 is used when a product’s customs code appears in Annex I but the product itself is outside the EUDR.
In practice, a shipment without a valid reference number cannot clear customs. That is the first consequence most companies will feel, long before any fine.
Which goods are caught
What counts is when a product is placed on the EU market, not when it was ordered or shipped. Goods placed on the market from 30 December need a statement, even if the purchase order dates from the summer. Goods already placed on the market before that date are generally outside the new obligations.
Timber has its own transition. Timber and timber products produced before 29 June 2023 and placed on the market from 30 December 2026 stay under the old EU Timber Regulation until 31 December 2029.
The product list itself changed on 18 September 2026. Cattle leather and some rubber articles left Annex I; soluble coffee, frozen cattle tongues and some palm-based products join on 30 December 2027. See EUDR Annex I has changed.
Who must comply on 30 December, and who later
Company | From | What they do |
|---|---|---|
Large and medium operators, and micro and small operators established after 31 December 2024 | 30 Dec 2026 | Due diligence (simplified where Article 13 applies) and a statement before placing or exporting |
Micro and small operators established by 31 Dec 2024 (not EUTR timber) | 30 Jun 2027 | Due diligence and statements; micro and small primary operators in low-risk countries file a one-time simplified declaration |
Micro and small operators placing timber covered by the old EUTR | 30 Dec 2026 | As large and medium operators |
Downstream operators and traders | 30 December 2026, any size | No statement of their own; collect and keep the reference numbers for five years where the supplier is an operator, and act on new information |
Not sure which row you are in? The EUDR Obligations Checker tells you in two minutes, and our guide to operators versus traders explains the roles.
10-week plan
Know what to do each week until EUDR enforcement starts on 30 December. Our EUDR checklist sets out the order of work, from scope to test filings.
EUDR enforcement: what authorities will do from day one
Competent authorities plan risk-based checks each year. They must check at least 1% of operators sourcing from low-risk countries, 3% from standard-risk countries and 9% from high-risk countries. They can also act on substantiated concerns from third parties, such as NGOs, competitors or journalists, and they share information through the EU Information System.
Penalties are set nationally, and several member states are still passing their laws. That does not delay anything for companies: the regulation applies directly. We compare the national regimes in EUDR Penalties by Member State.
What does not happen
- No grace period. The Commission proposed a six-month EUDR enforcement grace period in October 2025. Parliament and Council replaced it with a full one-year postponement instead, so 30 December 2026 is the real start.
- No fine wave on 31 December. Checks are risk-based and fines follow investigations. The immediate risk is goods held at customs and customers who cannot buy from you without a reference number.
- No exemption for certified supply chains. FSC, PEFC and similar schemes provide useful evidence but do not replace due diligence.
Could the date move again?
The Commission’s May 2026 review confirmed the dates. Legal observers quoted in the trade press in October 2026 called a third delay possible but less likely than application on schedule. Plan for 30 December. If it moves, the supplier data you collected is still the core of every filing.
Be ready before 30 December
The slowest step is supplier and plot data, so start there. In EUDR Passport, setting up product profiles and collecting supplier data is free, and suppliers answer in their own free account. The risk assessment costs €90 per product profile per year, and you file as many statements to TRACES as you need, without fees per shipment. Our 10-week EUDR checklist sets out the order of work.
Frequently asked questions
No. The grace period proposed in October 2025 was replaced by a one-year postponement, so obligations apply in full from 30 December 2026.
It cannot clear customs, because the declaration must carry a valid DDS reference number. Authorities can also confiscate non-compliant goods and the revenue from them.
Goods already placed on the EU market before 30 December are generally outside the new obligations. Goods placed on the market from that date need one.
No. Under the amended EUDR they collect and keep the upstream reference numbers, keep records for five years and act on new information.
No. Checks are risk-based, with minimum annual rates of 1%, 3% and 9% of operators depending on the risk level of the sourcing country.
30 DECEMBER 2026
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