When analyzing EUDR requirements for your business, the first step is to verify the presence of commodities and their corresponding CN codesin your company's structure. Identifying a CN code listed in Annex I of the Regulation is the starting point for further assessment and determines the need for an in-depth analysis.
Effective dates for obligations
The current effective dates for these obligations are:
- December 30, 2026, for large and medium-sized enterprises,
- June 30, 2027, for small and micro-enterprises.
The above dates are set out in the amending act, Regulation (EU) 2025/2650 of the European Parliament and of the Council of 19 December 2025, amending Regulation (EU) 2023/1115 as regards certain obligations for operators and traders. Initially, the requirements for trading in the commodities listed in the annex were to apply from December 30, 2024, and June 30, 2025, but this has been postponed twice.
Which entities face the most extensive obligations
The scale of regulatory obligations is tailored to the size of the enterprise and the role it plays regarding the commodities covered by the EUDR. The most significant obligations fall on companies that place products covered by the regulation on the European market or export them outside of Europe. Under the regulation, they become the operator for a given commodity. It is the operator who bears the responsibility for due diligence before placing products on the market or exporting them. Fulfilling due diligence obligations includes:
- collecting information confirming compliance with requirements;
- applying risk assessment measures (as defined by the EUDR regulation);
- applying risk mitigation measures (as defined by the EUDR regulation).
In practice, this means the necessity of gathering information that proves that products did not contribute to deforestation after December 30, 2020, including information on:
- the exact quantity of the relevant commodities;
- the country of production of the given commodity;
- the geolocation of all plots of land where the commodity was produced (as defined by the EUDR regulation);
- the date and time range of production.
Additionally, operators will be required to register in the TRACES system and submit a due diligence statement.
The scope of obligations is the same for every operator – regardless of whether they are a micro, small, medium, or large enterprise. The only difference for them is the effective date of these obligations, as mentioned in the previous paragraph.
Nasze usługi w zakresie oświadczeń EUDR
Wesprzemy Twoją firmę w spełnieniu wymogów rozporządzenia EUDR. Wskażemy, które produkty mogą być objęte wymaganiami oraz sporządzimy kompleksową analizę gotową do przedstawienia odpowiednim organom.
Exception
Operators, that are micro-entities and small primary entities constitute an exception, to which simplified requirementswill apply. This is a narrow category of operators who:
- are located in a low-risk country,
- place for the first time a product on the EU market or export it from it for the first time ,
- while producing the given commodity themselves.
These entities are not required to complete the full due diligence procedure, have less data to collect, and face fewer administrative burdens.
‘Traders’ and ‘traders further down the supply chain’
Traders and traders further down the supply chain are not required to carry out the full due diligence process as defined by the EUDR. For SMEs (micro, small, and medium-sized enterprises), their obligations are essentially limited to ensuring product traceability, which means collecting and storing information on who the product was purchased from and who it was sold to. Non-SME traders, i.e., large enterprises, in addition to traceability and data storage obligations, are also required to register in the TRACES system and provide the required information within the supply chain.
In practice, this means that the lightest obligations under the EUDR system apply to micro, small, and medium-sized enterprises operating further down the supply chain, which do not place products on the EU market for the first time, but merely participate in their further distribution.
In the next part, we will discuss the goods verification process in detail, examine the CN codes found in Annex 1 of the regulation, and look at the recently introduced changes.
Part 1 of the article is available here: LINK
