Am I Affected by EUDR? Quick Decision Tree
The quickest way to determine if EUDR applies to your business is to answer three simple questions:
EUDR Applicability Test
- Question 1: Do you place products on the EU market (sell, import, or make available) OR export products from the EU?
- Question 2: Do those products contain any of the seven regulated commodities (cattle, cocoa, coffee, palm oil, rubber, soy, wood) or their derivatives?
- Question 3: Were those commodities produced or harvested after December 31, 2020?
If you answered YES to all three questions: You need to comply with EUDR.
The regulation applies regardless of your company size, location, or whether you're a manufacturer, importer, distributor, or retailer. Even businesses outside the EU are affected if their products enter the European market.
Critical Point: EUDR distinguishes between two main categories of economic actors: operators and traders. Your obligations differ significantly based on which category you fall into.
Operators: First Placers on the EU Market
Who Qualifies as an Operator?
An operator is any natural or legal person who, in the course of commercial activity, places relevant products on the EU market for the first time, or exports such products.
You're an Operator if you:
- ✓ Import covered commodities or products into the EU from third countries
- ✓ Produce covered commodities within the EU and place them on the market
- ✓ Export covered commodities or products from the EU to third countries
- ✓ Are the first entity to make a relevant product commercially available in the EU
Operator Obligations: Full Due Diligence
Operators bear the heaviest compliance burden under EUDR. Your responsibilities include:
📋 Information Collection
- • Product description and quantity
- • Country of production
- • GPS coordinates (latitude/longitude) of production plots
- • Production/harvest dates
- • Supplier and customer information
🔍 Risk Assessment
- • Evaluate deforestation risk by country
- • Check commodity-specific risk factors
- • Verify legality of production
- • Assess supplier compliance history
- • Document risk analysis conclusions
🛡️ Risk Mitigation
- • Request additional information if risks found
- • Conduct independent audits
- • Seek third-party verification
- • Implement corrective measures
- • Maintain mitigation documentation
📤 DDS Submission
- • Submit Due Diligence Statement (DDS) to authorities
- • Receive unique DDS reference number
- • Provide DDS number to customers
- • Retain records for 5 years
- • Update DDS if circumstances change
Common Operator Examples
- Coffee roaster importing green coffee beans from Colombia → Operator
- Furniture manufacturer importing timber from Indonesia → Operator
- Chocolate maker importing cocoa from Ghana → Operator
- Cosmetics brand importing palm oil derivatives from Malaysia → Operator
- EU timber company exporting wood products to UK → Operator (exporter)
Traders: Supply Chain Intermediaries
Who Qualifies as a Trader?
A trader is any person in the supply chain, other than the operator, who makes relevant products available on the EU market in the course of commercial activity.
You're a Trader if you:
- ✓ Purchase products already on the EU market from an operator or another trader
- ✓ Resell those products to other businesses or consumers
- ✓ Distribute products through the supply chain within the EU
- ✓ Retail products containing covered commodities to end consumers
- ✓ Are NOT the first to place the product on the EU market
Trader Obligations: Simplified Traceability
Traders have lighter obligations compared to operators, focused primarily on traceability and record-keeping:
Trader Requirements:
-
1. Collect DDS Reference Number
Obtain the unique DDS reference number from your supplier (the operator or previous trader)
-
2. Maintain Supplier Information
Keep records of who supplied you with the relevant products
-
3. Maintain Customer Information
Record who you sold or transferred the products to (if applicable)
-
4. Retain Records for 5 Years
Preserve all traceability documentation for mandatory 5-year period
-
5. Provide Information to Authorities
Make records available to competent authorities upon request
Important: Traders do NOT need to submit their own Due Diligence Statements. However, you MUST verify that your supplier has provided a valid DDS reference number. Without it, you cannot demonstrate compliance.
Common Trader Examples
- Coffee shop buying roasted coffee from EU-based roaster → Trader
- Furniture retailer selling imported furniture to consumers → Trader
- Chocolate distributor buying from EU chocolate manufacturer → Trader
- Restaurant purchasing coffee, cocoa products, or beef from EU suppliers → Trader
- Wholesaler distributing timber products within the EU → Trader
Operator vs Trader: Key Differences
| Aspect | Operator | Trader |
|---|---|---|
| Role | First placer on EU market or exporter | Supply chain intermediary |
| Due Diligence | Full due diligence required | No due diligence (traceability only) |
| GPS Coordinates | Must collect from suppliers | Not required |
| Risk Assessment | Mandatory | Not required |
| DDS Submission | Must submit to authorities | Not required |
| DDS Reference | Receives from authorities after submission | Collects from supplier |
| Record Retention | 5 years | 5 years |
SME-Specific Considerations
Do SMEs Get Special Treatment Under EUDR?
Small and medium-sized enterprises (SMEs) do NOT get exemptions from EUDR, but they do receive some accommodations:
✓ Extended Deadline
SMEs have until June 30, 2026 to comply (18 months after large enterprises' December 30, 2024 deadline)
✓ Simplified Procedures
Micro and small enterprises may apply simplified due diligence for standard risk products from low-risk countries
✓ EU Support
European Commission committed to providing guidance and assistance specifically for SMEs
SME Size Classification (EU Definition)
Your SME category affects which simplified procedures you can access:
| Category | Employees | Annual Turnover | Simplified DD Eligible? |
|---|---|---|---|
| Micro | ≤ 10 | ≤ €2 million | Yes |
| Small | ≤ 50 | ≤ €10 million | Yes |
| Medium | ≤ 250 | ≤ €50 million | Limited |
| Large | > 250 | > €50 million | No |
Critical Misunderstanding to Avoid: Being an SME does NOT mean you can skip compliance. You still need GPS coordinates, risk assessments, and DDS submissions. The "simplified" procedures only apply to specific low-risk scenarios and reduce some administrative burden—they don't eliminate the core requirements.
Sector-by-Sector Breakdown: Who in Your Industry is Affected?
☕ Coffee Importers and Roasters
Covered: All coffee products, including green coffee beans, roasted coffee, instant coffee, coffee extracts
- Operators: Coffee importers bringing beans from origin countries, EU-based coffee plantations, coffee exporters
- Traders: Coffee roasters buying from EU importers, coffee shops purchasing from roasters, retailers selling packaged coffee
- Key Challenge: Smallholder farm GPS coordinates from cooperatives (often 100+ farmers per batch)
- Compliance Focus: Harvest dates, farm-level geolocation, cooperative certification status
🍫 Cocoa and Chocolate Manufacturers
Covered: Cocoa beans, cocoa paste, cocoa butter, cocoa powder, chocolate products
- Operators: Cocoa bean importers, chocolate manufacturers importing cocoa, cocoa product exporters
- Traders: Chocolate distributors, confectionery retailers, bakeries using chocolate as ingredient
- Key Challenge: West African sourcing (Ghana, Ivory Coast = high deforestation risk areas)
- Compliance Focus: Plot-level GPS for smallholder farms, cooperative membership tracking, cocoa butter vs mass differentiation
🪑 Furniture Makers and Timber Importers
Covered: Timber (logs, sawn wood), wood products (furniture, flooring, paper), wood pulp, printed materials
- Operators: Timber importers, furniture manufacturers importing wood, paper producers, wood product exporters
- Traders: Furniture retailers, lumber distributors, construction material suppliers
- Key Challenge: FSC/PEFC certification ≠ EUDR compliance (additional GPS requirements)
- Compliance Focus: Forest plot GPS coordinates, species-level tracking, engineered wood component traceability
🧴 Cosmetics and Personal Care Brands
Covered: Products containing palm oil or its derivatives (soaps, shampoos, lotions, makeup)
- Operators: Cosmetics brands importing palm oil derivatives, beauty manufacturers, personal care exporters
- Traders: Beauty retailers, pharmacy chains, e-commerce beauty platforms
- Key Challenge: 200+ palm oil derivatives in formulations (hard to identify which ingredients are covered)
- Compliance Focus: Ingredient-level traceability, plantation GPS, natural vs synthetic ingredient differentiation
🥩 Premium Butchers and Leather Goods Makers
Covered: Cattle products (beef, leather, processed meat, leather goods)
- Operators: Meat importers, leather importers, EU cattle farmers placing meat on market, leather goods manufacturers importing hides
- Traders: Butcher shops, leather retailers, restaurants serving beef, tanneries processing imported hides
- Key Challenge: Brazilian/Argentine sourcing (Amazon deforestation risk), ranch-level GPS collection
- Compliance Focus: Ranch GPS coordinates, slaughterhouse documentation, dual-use product tracking (meat + leather from same animal)
🍴 Restaurants and Hotel Groups
Covered: If serving coffee, cocoa products (chocolate desserts), beef, or using wooden furniture/paper
- Operators: Rare (only if importing directly from origin countries)
- Traders: Most restaurants (buying from EU-based suppliers)
- Key Challenge: Multiple EUDR commodities on menu, seasonal ingredient sourcing, supplier DDS collection
- Compliance Focus: Collecting DDS reference numbers from coffee, cocoa, beef suppliers; maintaining 5-year traceability records
🌱 Vegan Food Brands and Tofu Manufacturers
Covered: Products containing soy (tofu, tempeh, soy protein isolate, soy milk)
- Operators: Soy importers, tofu manufacturers importing soybeans, plant-based protein brands, soy product exporters
- Traders: Health food stores, vegan product retailers, restaurants serving tofu/tempeh
- Key Challenge: South American soy (Brazil, Argentina = high deforestation risk), multiple soy derivative forms
- Compliance Focus: Farm-level soy GPS, non-GMO vs conventional tracking, soy protein isolate vs whole bean differentiation
🛞 Tire Manufacturers and Rubber Product Makers
Covered: Products containing natural rubber (tires, rubber seals, latex gloves, rubber hoses)
- Operators: Tire manufacturers importing natural rubber, industrial rubber goods makers, latex product importers
- Traders: Tire retailers, industrial supply distributors, automotive parts sellers
- Key Challenge: Natural vs synthetic rubber differentiation (only natural rubber covered), Southeast Asian sourcing
- Compliance Focus: Plantation GPS (Indonesia, Vietnam, Thailand), natural rubber percentage in blended products
Exemptions and Edge Cases: When EUDR Doesn't Apply
Products Explicitly Exempt
- Recycled Products: Furniture made from 100% recycled wood is exempt (no new deforestation)
- Products Produced Before December 31, 2020: EUDR only applies to commodities produced/harvested after this cutoff date (vintage furniture, antiques exempt)
- Non-Commercial Use: Personal imports for own use (not for sale or commercial activity)
- Synthetic Alternatives: Synthetic rubber, synthetic leather, artificial palm oil alternatives (not derived from covered commodities)
Geographic Exemptions?
Myth: "I only source from Europe, so I'm exempt."
Reality: NO geographic exemptions. EUDR applies to commodities from ALL countries, including EU member states. Even Norwegian timber or Spanish cattle must comply if placed on the EU market after December 31, 2020.
Size-Based Exemptions?
Myth: "I'm a micro-enterprise, so I'm exempt."
Reality: NO size exemptions. All operators and traders must comply, regardless of company size. SMEs get extended deadlines and simplified procedures for certain scenarios, but not exemptions.
Certification-Based Exemptions?
Myth: "I buy FSC-certified timber / Fair Trade coffee, so I'm exempt."
Reality: NO certification exemptions. Third-party certifications (FSC, PEFC, Rainforest Alliance, Fair Trade) are helpful for risk assessment but do NOT replace EUDR requirements. You still need GPS coordinates, risk assessments, and DDS submissions.
Complex Edge Cases
Multi-Ingredient Products (e.g., Chocolate Bars)
Rule: Only EUDR-covered ingredients need tracking. For a chocolate bar: cocoa is covered (track GPS), but sugar, milk, vanilla are NOT covered (no GPS needed).
Dual-Role Businesses (Operator + Trader)
Rule: You can be both. Example: A coffee roaster who imports green beans (Operator) and also resells some to other roasters (Trader for those transactions). You must fulfill both sets of obligations for respective transactions.
E-Commerce Platforms (Amazon, eBay)
Rule: If you're a marketplace facilitator making products available, you're a Trader. You must collect DDS reference numbers from sellers and maintain traceability records.
Re-Export Scenarios (Import to EU, then export to non-EU)
Rule: If you import to EU and re-export within 30 days without processing, special simplified procedures may apply. However, you're still an Operator for both the import and export transactions.
Self-Assessment Quiz: Determine Your EUDR Role
Interactive EUDR Role Assessment
Scenario 1: Small Coffee Roastery
You own a specialty coffee roastery in Berlin. You import green coffee beans directly from a cooperative in Colombia, roast them, and sell packaged coffee to local cafés.
Show Answer
Role: You are an OPERATOR when importing the green beans (first placing on EU market). You are also a TRADER when selling roasted coffee to cafés (making available on market after initial placement).
Obligations: Full due diligence, GPS coordinates from Colombian farms, risk assessment, DDS submission for imports. Provide DDS reference numbers to café customers.
Scenario 2: Italian Furniture Retailer
You run a furniture store in Milan. You purchase wooden furniture from various Italian manufacturers who source timber from Scandinavia. You sell directly to consumers.
Show Answer
Role: You are a TRADER (products already on EU market from Italian manufacturers).
Obligations: Collect DDS reference numbers from each Italian manufacturer. Maintain supplier records showing which manufacturer supplied which furniture. Keep customer sales records. Retain all records for 5 years. NO need to submit your own DDS or collect GPS coordinates.
Scenario 3: French Chocolate Manufacturer
You manufacture artisan chocolate in Lyon. You import cocoa beans from Ivory Coast, make chocolate bars with EU-sourced sugar and milk, and sell to retailers across France and export some to Switzerland.
Show Answer
Role: You are an OPERATOR for both importing cocoa beans AND exporting chocolate to Switzerland.
Obligations: Full due diligence for cocoa imports (GPS from Ivory Coast farms, risk assessment of West African sourcing, DDS submission). Only cocoa needs tracking (sugar/milk exempt). Provide DDS reference numbers to French retailers. Submit separate DDS for exports to Switzerland.
Scenario 4: Restaurant Chain
You operate 15 restaurants across Spain. You purchase coffee from a Spanish coffee roaster, chocolate desserts from a French supplier, and beef from an Italian meat distributor.
Show Answer
Role: You are a TRADER for all purchases (products already on EU market from other EU suppliers).
Obligations: Collect DDS reference numbers from: (1) Spanish coffee roaster, (2) French chocolate supplier, (3) Italian meat distributor. Maintain records linking each DDS to products served. Retain records for 5 years. NO GPS collection or risk assessment required.
Scenario 5: Online Cosmetics Marketplace
You run an e-commerce platform in Germany where third-party beauty brands list and sell products containing palm oil derivatives.
Show Answer
Role: You are a TRADER (facilitating making products available on EU market).
Obligations: Collect DDS reference numbers from each seller/brand for products containing palm oil derivatives. Maintain records of which sellers provide which products. Implement system to verify sellers have valid DDS before allowing product listings. Retain records for 5 years. Consider terms of service requiring sellers to provide DDS.
Next Steps for Your Business
If You're an Operator:
- 1. Map Your Supply Chain
- • Identify all suppliers of EUDR-covered commodities
- • Determine countries of origin
- • Create commodity inventory (what, how much, from where)
- 2. Collect GPS Coordinates
- • Request geolocation data from all suppliers (latitude/longitude of production plots)
- • For smallholder cooperatives: work with cooperative managers to aggregate farmer data
- • Verify GPS accuracy with mapping tools
- 3. Conduct Risk Assessment
- • Check country risk levels (EU country benchmarking system)
- • Evaluate commodity-specific deforestation risks
- • Assess supplier compliance history
- • Document findings and mitigation measures
- 4. Prepare for DDS Submission
- • Compile all required information
- • Ensure data completeness and accuracy
- • Submit DDS through EU Information System (when operational)
- • Retain DDS reference numbers for customers
- 5. Establish Record-Keeping System
- • Implement 5-year retention for all compliance documentation
- • Track DDS reference numbers by shipment/batch
- • Maintain supplier and customer traceability
If You're a Trader:
- 1. Identify EUDR-Relevant Products
- • Review product catalog for covered commodities
- • Flag products requiring DDS reference numbers
- • Determine which suppliers provide EUDR-covered products
- 2. Request DDS Reference Numbers from Suppliers
- • Contact all suppliers of EUDR-covered products
- • Request DDS reference numbers for each shipment/delivery
- • Verify DDS numbers are valid (format: unique identifier from EU system)
- • Refuse deliveries without valid DDS references
- 3. Implement Traceability System
- • Link each DDS reference to corresponding products
- • Maintain supplier information (name, address, contact)
- • If reselling: track customer information for onward traceability
- 4. Establish Record Retention
- • Store all DDS references, supplier records, customer records for 5 years
- • Ensure records are easily retrievable for authority inspections
- • Consider digital system for efficient management
- 5. Update Procurement Processes
- • Add DDS reference number field to purchase orders
- • Train procurement team on EUDR requirements
- • Establish supplier communication protocols
Compliance Deadlines by Company Size
| Company Size | Compliance Deadline | Time Remaining |
|---|---|---|
| Large Enterprises (>250 employees or >€50M turnover) | December 30, 2024 | DEADLINE PASSED |
| SMEs (Micro, Small, Medium) | June 30, 2026 | ~19 months remaining (as of Nov 2025) |
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