Regulations •

EUDR: The EU Deforestation Regulation and the Digital Product Passport

What is the EUDR (Regulation (EU) 2023/1115)? Which products are covered, the due diligence and geolocation requirements, the timeline from 30 December 2026 and how the EU Deforestation Regulation relates to the Digital Product Passport.

Author: myDPP Team

EUDR: The EU Deforestation Regulation and the Digital Product Passport

Key takeaways

The EU Deforestation Regulation (EUDR, Regulation (EU) 2023/1115) bans the trade of products that have contributed to deforestation or forest degradation. It covers seven commodities - cattle, cocoa, coffee, oil palm, rubber, soya and wood - and a wide range of derived products such as leather, chocolate, furniture, paper and tyres. Anyone who places these goods on the EU market, exports them, or trades them must carry out due diligence, collect geolocation data for all plots of land where the raw materials were produced, and submit a due diligence statement (DDS) through a central EU information system. After two postponements, the EUDR applies to large and medium-sized companies from 30 December 2026 and to micro and small enterprises from 30 June 2027. This article explains what the EUDR requires and why the traceability and product data it demands rely on the same data foundation as the Digital Product Passport (DPP).

If you would like to get familiar with the Digital Product Passport first, we recommend the introductory article Digital Product Passport in 15 minutes: what DPP is and why the EU is introducing it.

What is the EUDR?

The EU Deforestation Regulation is the EU’s central rule against imported deforestation. Its goal is to ensure that EU consumption of certain commodities no longer contributes to the clearing and degradation of forests worldwide. The regulation entered into force on 29 June 2023 and replaces the older EU Timber Regulation (EUTR), significantly widening its scope.

At the heart of the EUDR is a market access ban: affected goods may only be placed on the EU market, made available, or exported if three conditions are met simultaneously. Responsibility rests with operators - those who first place goods on the market or export them - and with traders.

Which commodities and products are covered?

The EUDR covers seven commodities and a long list of derived products, defined in Annex I of the regulation by customs codes:

  • Cattle - e.g. beef, leather, hides
  • Cocoa - e.g. cocoa beans, chocolate
  • Coffee
  • Oil palm - e.g. palm oil and derivatives
  • Rubber - e.g. tyres, rubber goods
  • Soya - e.g. soybeans, soybean oil, animal feed
  • Wood - e.g. sawn timber, furniture, paper, pulp, printed products

Particularly relevant for product-level compliance: wood ends up in furniture, and rubber and leather end up in footwear, textiles and vehicle parts. This means the EUDR scope overlaps with product groups that also fall under the Ecodesign for Sustainable Products Regulation and the Digital Product Passport.

The three EUDR conditions

Affected products may only be traded if they are cumulatively:

  1. Deforestation-free: the raw materials were produced on land that was not subject to deforestation after 31 December 2020. For wood, there must also be no forest degradation.
  2. Produced legally: production complies with the relevant legislation of the country of production (land-use rights, environmental protection, labour law, tax, trade rules).
  3. Covered by a due diligence statement (DDS) submitted in the EU information system before placing on the market.

Due diligence: geolocation, risk assessment, DDS

The core of the EUDR is a three-step due diligence obligation:

1. Information requirements

Operators must collect information about the goods - description, quantity, country of production, and above all the geolocation coordinates of all plots of land where the commodities were produced. These geolocation data are the key innovation: they make it possible to trace every consignment back to the specific plot and to cross-check it against satellite data.

2. Risk assessment

Using the collected information, operators must assess the risk that the goods are non-compliant. Country benchmarking plays a role here: the EU classifies producer countries as low, standard or high risk. Goods from low-risk countries benefit from simplified due diligence.

3. Risk mitigation

Where the risk is not negligible, operators must take measures to reduce it - such as additional evidence, audits or independent checks.

The due diligence statement is then submitted electronically through the central EU information system (built on the TRACES platform). The system issues a reference number that can be passed along the supply chain.

EUDR timeline: when does it apply?

The application of the EUDR has been postponed twice. The current status:

  • 29 June 2023: EUDR enters into force.
  • December 2024: first postponement by one year.
  • December 2025: second postponement by a further year, together with a simplification package that significantly reduces the volume of data submissions (the Commission expects around 75 percent lower annual compliance costs).
  • 30 December 2026: application begins for large and medium-sized companies.
  • 30 June 2027: application begins for micro and small enterprises and natural persons.

The Commission has confirmed there will be no further postponement and that the text will not be reopened. Companies should therefore prepare firmly for 30 December 2026.

Why EUDR and the Digital Product Passport belong together

At first glance, the EUDR and the Digital Product Passport are two separate obligations with different filing routes. In substance, however, both demand the same underlying principle: product-level, traceable and digitally available data about the origin and composition of a good.

  • The EUDR requires origin, geolocation and supply chain evidence per batch.
  • The Digital Product Passport requires material composition, origin, supply chain actors and lifecycle data.

For product groups such as furniture (wood) or footwear and textiles (leather, rubber), both frameworks hit the same manufacturer. A company that structures the underlying origin and material data once - cleanly, per product and machine-readable - can reuse it for both purposes instead of maintaining separate data silos.

An important clarification: the Digital Product Passport does not replace EUDR filing - the due diligence statement is still submitted in the EU information system. But the DDS reference number and the associated origin data can be stored in the product passport and surfaced through the same QR code that resolves to the DPP. myDPP maps this data foundation in a product-centric way and serves it via the GS1 Digital Link.

What should companies do now?

1. Check whether you are affected

Compare your product portfolio against Annex I of the EUDR. Do your products contain wood, leather, rubber, coffee, cocoa, soya or palm oil?

2. Map the supply chain

For each affected good, determine the country of production and the geolocation of the plots of land. Clarify with your suppliers who provides the geolocation data.

3. Determine your role

Are you an operator or a trader? This determines whether you submit your own due diligence statement or pass on an existing DDS reference number.

4. Build the data foundation

Capture origin, material and supply chain evidence in a structured, product-level way - not in separate lists per compliance obligation.

5. Consolidate EUDR and DPP data

Use a single product data source for EUDR due diligence, the Digital Product Passport and other sustainability obligations, so that origin and material data are maintained only once.

Frequently asked questions (FAQ)

What is the EUDR in simple terms?

The EUDR is an EU regulation that bans the trade of products whose raw materials contributed to deforestation after 31 December 2020. Affected companies must prove origin, collect geolocation data and submit a due diligence statement.

Which products does the EUDR cover?

Seven commodities - cattle, cocoa, coffee, oil palm, rubber, soya and wood - and derived products such as leather, chocolate, furniture, paper, tyres and soya animal feed.

When does the EUDR apply?

After two postponements, it applies to large and medium-sized companies from 30 December 2026 and to micro and small enterprises from 30 June 2027.

What is a due diligence statement (DDS)?

The due diligence statement is an electronic declaration in which a company confirms it has fulfilled its due diligence obligation. It is submitted in the EU information system before placing goods on the market and receives a reference number.

What does the EUDR have to do with the Digital Product Passport?

Both rely on product-level origin, material and supply chain data. The DPP does not replace EUDR filing, but it can carry the DDS reference number and origin data. A shared data foundation avoids duplicate data capture.

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