EU Deforestation Regulation (EUDR): due diligence duties and capacity

Short answer: The EU Deforestation Regulation (EUDR, Regulation (EU) 2023/1115) requires companies that place cattle, cocoa, coffee, oil palm, rubber, soya or wood, and products made from them, on the EU market or export them to carry out due diligence and file a due diligence statement. The obligations apply from 30 December 2026, and from 30 June 2027 for micro and small operators.

This briefing is for legal, compliance and procurement leads in manufacturing, retail and food businesses in Germany and for Swiss companies supplying the EU. It explains EUDR compliance after the December 2025 amendment and what capacity the implementation needs.

What is the EUDR about?

The EUDR allows the covered commodities and products to be placed on the market, made available or exported only if three conditions are met (Art. 3):

• Deforestation-free: the commodities come from land that has not been deforested after 31 December 2020; for wood, harvesting has not caused forest degradation after that date (Art. 2(13)).
• Legally produced: production complies with the law of the country of production, including land use rights, environmental protection, labour and human rights, tax and anti-corruption rules (Art. 2(40)).
• Covered by a statement: a due diligence statement or a simplified declaration exists for the products.

Annex I lists the products in scope by customs code, for example chocolate, wooden furniture, paper and new pneumatic rubber tyres. The EUDR progressively replaces the EU Timber Regulation (EUTR). It has been amended twice: Regulation (EU) 2024/3234 postponed the date of application, and Regulation (EU) 2025/2650 of 19 December 2025 postponed it again and simplified the obligations along the supply chain.

Who does the EUDR apply to?

Obligations depend on a company's position in the supply chain. Since the December 2025 amendment, the EUDR distinguishes four groups.

Source: Regulation (EU) 2023/1115, consolidated version of 18 September 2026; compiled by Alpinum Solutions, November 2026.

For Swiss suppliers, Art. 7 is key: where a person established outside the EU places products on the market, the first person established in the EU that makes them available counts as the operator. The EU customer then carries the obligations and needs the Art. 9 information from the Swiss supplier, such as the geolocation of the plots of land.

EUDR deadlines and current status

The next deadline is 30 December 2026, when the obligations start to apply to all operators, downstream operators and traders except micro and small operators (Art. 38(2)). The other dates come from the regulation and from the European Commission.

Source: Regulation (EU) 2023/1115 (consolidated, 18 September 2026) and European Commission, accessed 10 November 2026. All deadlines at a glance are in the regulatory calendar for legal and compliance teams.

What companies need to do now

By the end of 2026, companies should know their role, which products are affected and where the data will come from. Operator due diligence has three parts (Art. 8 to 11): collect information, assess risk, mitigate risk. A proven approach:

1. Match products: compare the product range and purchasing with the customs codes in Annex I, including the newly added products.
2. Determine the role: decide for each entity and product flow whether it is an operator, downstream operator or trader and whether it counts as an SME.
3. Secure the data: update supply contracts so that suppliers provide quantity, country of production, geolocation of all plots with the production period and evidence of legality (Art. 9).
4. Assess and mitigate risk: apply the Art. 10 criteria, such as the country risk classification, and document measures such as additional documents or independent audits (Art. 11). Both must be reviewed at least once a year.
5. Build the organisation: operators that are not SMEs appoint a compliance officer at management level, have their procedures checked by an independent audit function (Art. 11(2)) and report publicly every year on their due diligence system (Art. 12(3)).
6. File statements: set up access to the Commission's information system and submit due diligence statements before placing products on the market or exporting them (Art. 4(2)).

Breaches are costly. For legal persons, the maximum fine set by Member States must be at least 4% of total annual EU-wide turnover (Art. 25(2)). The EUDR sits alongside other supply chain duties; how it relates to the CSRD, the CSDDD and national supply chain laws is covered in CSRD, CSDDD and supply chain laws after the Omnibus.

Which roles and how much capacity are needed?

EUDR compliance combines contract law, customs and trade law and supply chain compliance. Typical roles are:

• EUDR compliance officer: for non-SMEs, owns the due diligence system at management level.
• Trade compliance specialist: maps products to customs codes and links the EUDR with customs and export processes.
• Legal counsel for commercial contracts: updates supply and framework agreements to secure data, evidence and audit rights.
• Supply chain compliance analyst: collects supplier data, assesses risk and prepares due diligence statements.
• Project lead: coordinates procurement, logistics, IT, legal and compliance up to the date of application.

An experienced specialist working part-time is often enough for the initial assessment. Collecting data from many suppliers and updating large contract portfolios usually needs a project team. How manufacturers plan legal capacity for contracts and exports is covered in interim legal in industry and engineering.

How interim support helps

Interim specialists bring EUDR experience into the team when the in-house legal and compliance function is busy with day-to-day work. They work inside the company's team; the company directs the work and remains responsible for the due diligence statements.

Alpinum Solutions provides trade compliance specialists, compliance officers and commercial lawyers through staff leasing and freelancing, part-time or full-time, as individual specialists or as project teams. Alpinum Solutions typically presents two to four profiles per search; selected profiles are usually available within 48 hours, and the start date is agreed between the client and Alpinum. Sectors with assignments include Industry & Manufacturing, Retail & Consumer Goods and Mobility, Transport & Logistics. How companies organise similar screening processes for sanctions is covered in sanctions compliance: tasks, roles and capacity.

Frequently asked questions about EUDR compliance

When does the EUDR apply?

The EUDR has been in force since 29 June 2023. Following the December 2025 amendment, its obligations apply from 30 December 2026 to all operators, downstream operators and traders except micro and small operators. Micro and small operators established by 31 December 2024 follow on 30 June 2027 (not for EUTR timber products). Downstream operators and traders do not get this deferral. Products newly added to Annex I are covered from 30 December 2027.

What is a due diligence statement under the EUDR?

A due diligence statement is an electronic declaration that operators submit through the Commission's information system before placing products on the market or exporting them. It contains the Annex II information and confirms that due diligence has been carried out and that no or only negligible risk was found. By submitting it, the operator assumes responsibility (Art. 4(2) and (3)).

Do traders and downstream companies have to file their own statement?

As a rule, not since the December 2025 amendment. Downstream operators and traders record suppliers, customers and the reference numbers of due diligence statements and keep them for five years. Non-SMEs register in the information system. Where there are substantiated concerns, they must notify the competent authority and their customers without delay (Art. 5(5)).

Does the EUDR affect Swiss companies?

Yes, where they supply covered products to the EU. Under Art. 7, the first customer established in the EU then counts as the operator and carries the due diligence obligation. It needs data from the Swiss supplier, such as the country of production and the geolocation of the plots. Swiss suppliers should therefore clarify data flows and contracts with EU customers early.

What penalties apply for breaches?

Member States set the penalties. For legal persons, the maximum fine must be at least 4% of the previous year's total EU-wide turnover (Art. 25(2)). Penalties should strip out the economic gain from the breach and increase for repeated infringements.

Next step

Alpinum Solutions is the leading provider of interim legal & compliance in the DACH region and provides specialists for EUDR projects in Germany, Switzerland and Austria. Discuss your needs with us and we will show you suitable profiles.

• Sanctions, trade compliance and export control: specialists for trade and supply chain compliance
• CSRD, CSDDD and supply chain laws after the Omnibus
• Sanctions compliance: tasks, roles and capacity
• Regulatory radar: all articles on regulatory change
• Discuss your needs

Last updated: 10 November 2026.