EU Deforestation Regulation: December 30, 2026 Enforcement Deadline Confirmed for Large/Medium Operators — Seven Commodities, No De Minimis Threshold

The EU Deforestation Regulation (EUDR, Regulation (EU) 2023/1115 as amended by Regulation (EU) 2025/2650) will enter enforcement for large and medium operators and traders on December 30, 2026 — a confirmed and final date. Micro and small operators have until June 30, 2027 (except those already covered by the EU Timber Regulation, which face the December 30 deadline). The EUDR covers seven primary commodities (cattle, cocoa, coffee, oil palm, rubber, soya, and wood) and all Annex I derived products; there is no de minimis threshold. Primary operators — those who place products on the EU market for the first time or export them — must exercise due diligence, collect specific information per Annex III, and submit a due diligence statement confirming there is "no or only a negligible risk" that products are not deforestation-free and legally produced. Penalties are set by Member States with a minimum ceiling of 4% of the operator's EU-wide turnover. The EU Timber Regulation will be repealed upon EUDR entry into force; however it will continue to apply to relevant products produced before June 29, 2023 and placed on the market after December 30, 2026, up until December 31, 2029. For supply chain counsel: EUDR compliance has a hard December 30 deadline that is less than five months away. The Commission's simplification review (published May 2026) introduced some targeted exemptions and clarifications, but the core due diligence structure — deforestation-free and legally produced certification for all in-scope commodity products — remains. The Information System for submitting due diligence statements has been updated after its February 2026 access restriction period; operators should verify they can access and navigate the system.