EUDR deadlines: when the rules actually apply

For large and medium operators and traders, from 30 December 2026. For natural persons and micro and small undertakings established by 31 December 2024, from 30 June 2027. From those dates you cannot place a covered commodity on the EU market, or export it, without a valid Due Diligence Statement. The later date carries one exception: products that were already covered by the annex to the old EU Timber Regulation do not get the deferral.

This is the single most common EUDR error, and it is expensive in both directions. The Regulation carries four dates that do different jobs, and only two of them are deadlines.

31 Dec 2020 is the deforestation cut-off in Article 2. It is a property of the land, and it is the substantive test: was this plot cleared after that date. 29 Jun 2023 is entry into force under Article 38(1), and through Article 1(2) it is the production cut-off for scope: a product produced before it is out of the Regulation altogether. 30 Dec 2026 and 30 Jun 2027 are the dates of application under Article 38(2) and (3). They govern when your obligations bind, not whether a product is in scope.

In scope is not the same as obligation live now. A product placed on the market between 29 June 2023 and 29 December 2026 is inside the Regulation but inside the transitional period, so no statement was owed for it. Treating 30 December 2026 as a production cut-off is the mirror error, and it is the one that leaves importers believing older stock is automatically clean.

Both delays were about readiness, not repeal. The first, Regulation (EU) 2024/3234in December 2024, gave operators and the Commission’s information system another year. The second, Regulation (EU) 2025/2650 in December 2025, added a further year and a package of simplifications: a one-off simplified declaration for micro and small primary operators, and rules letting downstream operators rely on a statement filed upstream instead of repeating the work. The obligations themselves, and the 2020 cut-off, stayed intact.

31 December 2020. A commodity is only deforestation-free if it was produced on land that was not subject to deforestation after that date, and, for wood, harvested without inducing forest degradation after it. Wood has to satisfy both limbs. The cut-off is a property of the land and has never moved. Only the dates on which you must start proving it have. Note that only conversion to agricultural use counts as deforestation here: clearing forest to build a road is not deforestation under the EUDR, while replacing it with a plantation is.

The 30 June 2027 date is for natural persons and for micro and small undertakings established by 31 December 2024. Size is measured against the Accounting Directive thresholds, not the general SME recommendation: small means not exceeding at least two of a €5m balance sheet, €10m net turnover, and 50 employees. Everyone larger is on the 30 December 2026 date. EUDR for SMEs works the thresholds and the reliefs through properly.

Three things, in order. Confirm which of your products are covered and gather plot geolocation for each. Register in the Commission’s information system and practise filing a Due Diligence Statement. Then set up the five-year record-keeping. The plots are the long-lead item: collect them once and reuse them per shipment. The commodity guides say what is in scope for each of the seven.