Perguntas frequentes sobre o EUDR 2026
This Perguntas frequentes sobre o EUDR resource provides clear, authoritative answers to the most common questions on the EU Deforestation Regulation (Regulation (EU) 2023/1115). It is intended for compliance, procurement, customs and sustainability professionals who need accurate, up‑to‑date information on scope, deadlines, roles, compliance obligations, penalties and the role of the Due Diligence Statement (DDS).
The questions and answers below focus on the practical issues that determine if a company can place or export in‑scope products without interruption at the border, and reflect the current regulatory requirements.
EUDR FAQ 2026: Key Topics
- What is EUDR
- What is EUDR compliance?
- Who is affected by EUDR?
- Which products are covered by EUDR?
- Which HS codes are covered by EUDR?
- What is the difference between an operator and a trader?
- Does EUDR apply if I only buy from EU suppliers?
- Do SMEs have lighter obligations under EUDR?
- Has EUDR been postponed?
- When does EUDR come into force?
- What is the current status of EUDR?
- How do I comply with EUDR?
- What is a Due Diligence Statement (DDS) number and where do I find it?
- What does “deforestation-free” mean under EUDR?
- What geolocation data does EUDR require?
- What legality evidence does EUDR require?
- How is EUDR risk assessed?
- What are the penalties for non-compliance with EUDR?
- How do I choose the right EUDR compliance solution?
- Do I need EUDR software?
- Can you submit the Due Diligence Statement for us?
- What do you need from us to get started?
EUDR FAQ basics
What is EUDR?
The EU Deforestation Regulation, Regulation (EU) 2023/1115, prohibits placing seven commodities and their derived products on the EU market — or exporting them from it — unless they are deforestation-free, legally produced in the country of origin, and covered by a Due Diligence Statement. It entered into force on 29 June 2023 and replaces the earlier EU Timber Regulation.
What is EUDR compliance?
EUDR compliance means being able to demonstrate three things for every regulated product you place on the EU market: that it is deforestation-free against the 31 December 2020 cut-off, that it was produced legally in its country of origin, and that you operated a documented due diligence system before filing a Due Diligence Statement.
It is not a certificate you obtain. It is an ongoing operational obligation, evidenced by records you must be able to produce for a competent authority at any point during the following five years.
Who is affected by EUDR?
Any company placing an in-scope commodity or derived product on the EU market, or exporting it from the EU. That covers importers, manufacturers, distributors and retailers alike — but the weight of the obligation varies enormously depending on whether you are an operator or a trader, and on your company size.
Which products are covered by EUDR?
Seven commodities: cattle, cocoa, coffee, oil palm, rubber, soy and wood. Plus a long list of derived products in Anexo I — including leather, chocolate, palm oil derivatives, glycerol, natural rubber products and tyres, soy flour and oil, furniture, pulp, paper and charcoal.
The list is actively moving. The draft delegated act published in May 2026 proposes removing packaging and waste, and adding items such as soluble coffee and further palm oil derivatives. Separately, the European Parliament voted to exclude Chapter 49 products — printed books, newspapers and magazines — though that position was not final at last check.
Any scoping exercise carried out in 2024 or 2025 should be redone before you rely on it, and the current status of the delegated act confirmed for any product sitting close to the line.
Which HS codes are covered by EUDR?
Annex I of the regulation defines scope by CN code — the EU’s Combined Nomenclature, which extends the international HS system to eight digits. Scope is set at that level of granularity, not by product description.
This matters more than it sounds. Two products that are commercially identical can sit on opposite sides of the line depending on their classification, and companies regularly discover they are in scope for a product line they never associated with deforestation. Checking your actual customs classifications against the current Annex I is the single most reliable way to establish scope — and it is the first thing our readiness assessment does.
What is the difference between an operator and a trader?
An operator places an in-scope product on the EU market for the first time, or exports it. Regulation (EU) 2025/2650 added a third category — the downstream operator, meaning a company placing on the market products already covered by a statement filed upstream. A trader simply makes goods available further down the chain.
Only operators file a Due Diligence Statement. Downstream operators and traders that are not SMEs must register in the EU information system, but no longer file their own. The first downstream operator in the chain must collect and retain the reference number from its direct supplier; it is not obliged to pass that number further down.
You can be an operator for one product line and a downstream operator for another. The determination is made flow by flow, not company-wide.
Does EUDR apply if I only buy from EU suppliers?
Yes, but your obligations are usually far lighter. If the goods were already covered by a statement filed upstream, you do not repeat the due diligence. If you buy directly from the operator, you collect and retain their reference number. If you sit further down the chain than that, your obligations are lighter still.
The exception is if you transform those goods into a new in-scope product and place that on the market — at which point you become a downstream operator with your own registration duty.
Do SMEs have lighter obligations under EUDR?
It depends on whether the SME is an operator or a trader. SME traders have substantially reduced obligations — broadly, retaining supplier information and DDS reference numbers. Micro and small primary operators benefit from a simplified declaration route rather than a full DDS per consignment. But an SME that is an operator is not exempt from due diligence; it mainly gets more time.
EUDR FAQ : Timing, postponement and current status
Has EUDR been postponed?
It was postponed twice, but it is not being postponed again. The European Commission confirmed the current timeline in its simplification package of 4 May 2026 and stated explicitly that there would be no further delay.
The confusion is understandable. A large share of the guidance still circulating online — including pages ranking well in search — was written before the amendments and shows superseded dates. If a source tells you the deadline is 30 December 2025 or 30 June 2026, it is out of date.
When does EUDR come into force?
The regulation entered into force on 29 June 2023. The obligations apply from 30 de dezembro de 2026 for large and medium companies, and for micro and small companies in the timber sector, and from 30 de junho de 2027 for other micro and small companies.
Company size is determined by the EU Accounting Directive rather than headcount alone. Misclassifying yourself moves your deadline by six months in one direction or the other, so it is worth establishing formally rather than assuming.
EUDR FAQ: What is the current status of EUDR?
In force, dates confirmed, no further delay expected. The May 2026 simplification package delivered an updated guidance document, a fifth version of the FAQ, a draft delegated act amending the product scope, and changes to the EU information system. The Commission estimated the package would cut annual compliance costs by roughly 75%.
The one element still moving is the product scope. The delegated act amending Annex I proposed removing some items and adding others, so confirm the current list before concluding a product is out.
How long does it take to become EUDR compliant?
The paperwork is not what takes the time. Supplier data collection is, and how long that takes depends on your supply chain rather than on your provider. Suppliers who are already mapped, contactable and able to produce plot coordinates move quickly. Smallholders you have never dealt with directly, several tiers away, do not.
The honest answer for any specific company comes out of the readiness assessment, once we can see how far your existing data sits from what a statement requires.
EUDR FAQ: How to comply
How do I comply with EUDR?
Four steps.
- One: establish your scope and your role — which products, which CN codes, operator or trader, which deadline.
- Two: build a documented due diligence system covering information collection, risk assessment and risk mitigation.
- Three: collect the evidence — plot geolocation, legality documents, supply chain traceability — and assess the risk.
- Four: file a Due Diligence Statement in the EU information system and keep the records for five years.
The system must be reviewed at least annually, and companies that are not SMEs must publish an annual report on it. In practice, step three consumes eighty per cent of the effort, because it depends on suppliers who may be several tiers away and have no obligation to you beyond your contract.
What is a Due Diligence Statement (DDS) number and where do I find it?
A DDS is the formal declaration filed in the EU information system before regulated goods are placed on the market or exported. It contains the product description and quantity, the country of production, the geolocation of every plot where the commodity was produced, and supplier details.
Submitting a DDS is legally significant: the party submitting it assumes responsibility for the product’s compliance.
When a Due Diligence Statement is accepted, the EU information system issues a reference number — commonly called the DDS number — which identifies that statement. You retrieve it from the system after submission.
It has two jobs. It must be provided in the customs declaration for the relevant goods, and it must be passed to downstream customers so they can demonstrate that due diligence was carried out upstream. A missing or invalid reference number at the border is the most common reason a shipment is held, and it is entirely avoidable.
EUDR FAQ: Data and evidence
What does “deforestation-free” mean under EUDR?
It means the commodity was produced on land that has not been subject to deforestation after 31 de dezembro de 2020 — and, for wood, that it was harvested without inducing forest degradation after that date.
The cut-off is fixed and does not move with the application deadlines. Land cleared in 2021 makes a commodity non-compliant today, regardless of how long ago it happened or whether it was legal at the time.
One practical exception is worth knowing: goods placed on the EU market before the regulation applies are treated as old stock and fall outside it. That has real consequences for inventory planning in the run-up to the deadline.
EUDR FAQ: What geolocation data does EUDR require?
Coordinates for every plot of land where the commodity was produced. Polygons are required above a defined plot size; points are permitted below it. For cattle, the requirement attaches to the establishments where the animals were kept.
In practice the difficulty is rarely the requirement itself — it is that supplier data arrives with invalid geometry, overlaps, duplicates, mixed formats and points where polygons are needed. Cleaning it is a substantial part of the work.
What legality evidence does EUDR require?
Far more than most companies expect. The regulation’s definition of legality covers land use rights, environmental protection, forest-related rules including forest management and biodiversity conservation, third parties’ rights, labour rights, human rights protected under international law, the principle of free, prior and informed consent of indigenous peoples, tax, anti-corruption, and trade and customs regulations.
Land titles and harvest permits are the starting point, not the finish line. This is consistently the part of a programme that takes longest, because the documents differ in every country of production.
EUDR FAQ: Risk and enforcement
How is EUDR risk assessed?
Risk assessment is the second of the three due diligence steps, and the regulation sets out the criteria you must consider. They include the risk classification of the country or region of production, the presence of forests and of indigenous peoples, consultation and cooperation with those communities, the prevalence of deforestation in the area, the reliability and verifiability of your supplier information, the complexity of the supply chain, and the risk of circumvention or of mixing with product of unknown origin.
The conclusion has to be that risk is negligible. If it is anything more than that, you must take mitigation measures — additional information, independent surveys or audits, supplier support — and bring it down to negligible before placing the product on the market.
What is EUDR country benchmarking, and which countries are high risk?
The Commission classifies every country as low, standard or high risk. The classification determines two things: how deep your due diligence must go, and how often authorities must check you.
The first list was published in May 2025. Four countries are high risk — Russia, Belarus, Myanmar and North Korea, all of them under sanctions. Around 140 are low risk, including every EU member state and the United Kingdom, the United States, Canada, China, Japan and Australia. Around 50 sit at standard risk — and that group includes Brazil, Indonesia and Malaysia.
This distribution matters more than the mechanism. Sourcing from a low-risk country means you still collect the information and the geolocation, but you skip formal risk assessment and mitigation. Sourcing from a standard-risk country means the full process. In practice, most tropical commodity supply chains — coffee, cocoa, palm oil, natural rubber, soy — get no relief at all, while wood, pulp and paper sourced within Europe or North America are considerably lighter.
Minimum annual inspection rates are 9% of operators for high-risk origins, 3% for standard risk and 1% for low risk. The list is dynamic and reclassification cuts both ways, so it is worth monitoring rather than checking once.
What are the penalties for non-compliance with EUDR?
Fines of at least 4% of annual EU-wide turnover, confiscation of the goods and of the revenues derived from them, exclusion from public procurement and public funding, and temporary prohibition from placing products on the market. In practice, the first consequence most companies meet is a shipment held at the border.
EUDR FAQ: Choosing a solution
How do I choose the right EUDR compliance solution?
Start by working out which problem you actually have, because the market sells three different things and they are not interchangeable. Software automates workflow and filing — valuable if your data is already in reasonable shape and your suppliers are responsive. Consultoria builds the system and does the supplier work — valuable if you are starting from a blank page. Accredited verification provides third-party assurance — valuable if a customer or a scheme requires it.
Five questions worth asking any provider: What happens when a supplier does not respond? Who owns the plot data at the end of the engagement? Is deforestation screening built in-house or bought in, and from whom? Does the price scale with suppliers, plots or shipments? And can you show me what you produce for a competent authority inspection, not just a dashboard?
Be wary of anyone who tells you a certificate will make you compliant, and of any pricing model where the cost of adding suppliers is not made explicit — supplier count, not revenue, is what drives the real workload.
Do I need EUDR software?
It depends on scale. Below roughly fifty suppliers, a well-structured system and disciplined record-keeping will carry you, and software is an expense rather than a saving. Above a few hundred plots, manual handling becomes the bottleneck and a platform pays for itself.
What software does not solve is the hard part: getting a supplier in another country e another language to hand over plot boundaries and legal documents. No platform makes that conversation happen. We work alongside whichever platform you choose — or without one, if you do not need one.
Can you submit the Due Diligence Statement for us?
We prepare it, validate it against the system’s technical requirements, and support you through submission — but the declaration is filed by you. Submitting a DDS is the moment responsibility for compliance is assumed, and that decision sits best with the company that owns the supply chain. If you need a third party to file on your behalf, we will point you to providers who offer it.
What do you need from us to get started?
For the diagnostic: your product list with CN codes, your countries of origin, an indication of volumes, and whoever owns customs and procurement internally. That is enough to establish scope, role and size classification.
Everything else — supplier engagement, geolocation, legality evidence — comes after, and we do the heavy lifting on it.
Need support with EUDR compliance? Explore our EUDR Compliance Services.
