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EUDRCalendarEU

EU Deforestation Regulation deadlines and compliance calendar

Use this calendar to identify the EUDR date that applies to each operator and product, then schedule the evidence and system work that must finish first.

It separates binding application dates from earlier system and benchmarking milestones and from internal preparation dates.

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Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
4 sections5 primary sources
Overview

Regulation (EU) 2023/1115, the EU Deforestation Regulation (EUDR), applies most core obligations from 30 December 2026. A later date, 30 June 2027, applies to operators that were established as natural persons or micro or small undertakings by 31 December 2024, except for products covered by the annex. The calendar also needs separate entries for the , country-risk classification, and the timber transition. Classify the actor and product before choosing a deadline.

Section 1

Calendar milestones to track

These legal and operational milestones belong in an EUDR implementation calendar. An internal supplier cutoff or shipment freeze may need to fall earlier, but it is not a legal application date.

The later date is actor- and product-specific. It is not a general six-month grace period, and it does not cover products listed in the Annex to Regulation (EU) No 995/2010.

  • 29 June 2023: Regulation (EU) 2023/1115 entered into force; the consolidated text also treats all countries as initially assigned a standard level of risk under the benchmarking system from this date.
  • 4 December 2024: the Commission launched the Article 33 for due diligence statements; user registration opened in November 2024.
  • 26 May 2025: Commission Implementing Regulation (EU) 2025/1093 entered into force. Its Annex lists low- and high-risk countries, and every country not listed remains standard risk.
  • 30 December 2026: Articles 3 to 13, 16 to 24, 26, 31, and 32 apply, subject to the later-date rule. This cohort includes large and medium operators and micro and small operators dealing in products covered by the EUTR annex.
  • 30 June 2027: the same articles apply to operators established as natural persons or micro or small undertakings by 31 December 2024, except for products covered by the EUTR annex.
  • 30 December 2027: specific new Annex I product entries added by Regulation (EU) 2026/2102 apply, including frozen cattle tongues and coffee extracts. The amendment itself entered into force on 18 September 2026; apply its removals and exclusions separately from this later date.
  • 31 December 2029: Article 37(3) requires timber and timber products within the definition, produced before 29 June 2023 and placed on the market from this date, to comply with EUDR Article 3. Article 37(2) preserves the earlier timber regime until this date for that production cohort when placed on the market from 30 December 2026.
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This calendar helps assign owners for product scoping, supplier evidence, country-risk updates, Article 33 system work, and due diligence statement records before the applicable EUDR date.

Research workflow
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Section 2

What changes at the application dates

From the applicable date, relevant commodities and products must not be placed or made available on the EU market or exported unless they are deforestation-free, produced in accordance with relevant legislation of the country of production, and covered by a due diligence statement or simplified declaration as required.

Apply the date test by operator and product. A micro or small operator established by 31 December 2024 may fall into the 30 June 2027 cohort for one product but the 30 December 2026 cohort for a product covered by the EUTR annex.

  • Operators: complete Article 8 due diligence before placing on the market or exporting and submit the due diligence statement before the product movement that requires it.
  • Micro or small primary operators: when the Article 2 and 4a conditions apply, submit the one-time simplified declaration through the Article 33 system before placing on the market or exporting.
  • Downstream operators and traders: retain supplier and downstream recipient information, including due diligence statement reference numbers or declaration identifiers where relevant.
  • Non-SME downstream operators and non-SME traders: register in the Article 33 before placing, making available, or exporting relevant products.
Section 3

Country benchmarking and due diligence system milestones

Country risk changes both the operator's due diligence route and the competent authority's minimum check rate. Commission Implementing Regulation (EU) 2025/1093 now supplies the operative list: use its Annex for low- and high-risk countries and treat unlisted countries as standard risk. Check the current act again if the production origin changes or the Commission updates the list.

The Article 33 is a separate operational dependency. It records due diligence statements, simplified declarations, their identifiers, and required registrations. A system launch date does not postpone the legal requirement to have product evidence ready before the applicable market or export event.

  • Benchmarking workstream: record Implementing Regulation (EU) 2025/1093 or its successor, the country or part of country, the date checked, and the production origin used for each tier decision.
  • Simplified due diligence workstream: only use low-risk simplification after checking supply-chain complexity, circumvention risk, and mixing risk, and keep documentation showing negligible risk.
  • Information-system workstream: assign owners for registration, due diligence statement submission, simplified declaration submission, reference-number capture, and downstream communication.
  • Record workstream: keep due diligence statements for five years and keep downstream Article 5 information for at least five years where those obligations apply.
Section 4

Preparation tasks before the relevant date

Build the calendar backward from the first product movement on or after the applicable date for each operator-product combination. Show what must be ready before a purchase order, shipment, export, or market-placement decision is released.

Keep these tasks tied to maintained evidence rather than one-time status notes. The same records will support due diligence, authority requests, supplier follow-up, and downstream communication.

For each operator-product combination, give the calendar owner a row containing the applicable date, the evidence supporting later-date eligibility if claimed, the first planned market-placement or export event, an internal evidence cutoff, and an owner for each unresolved item. Treat an incomplete row as a planning hold until the responsible owner resolves the missing classification or evidence. This is an operational planning control, not an additional legal deadline.

  • Scope the product set: identify cattle, cocoa, coffee, oil palm, rubber, soya, wood, and Annex I derived products that may be placed, made available, or exported.
  • Classify the actor role: record whether each business unit acts as operator, downstream operator, trader, non-SME downstream operator, non-SME trader, or micro or small primary operator.
  • Collect Article 9 evidence: keep commodity/product description, quantity, country of production, supplier information, geolocation or permitted substitute data, and documentation showing deforestation-free and lawful production where required.
  • Assess and mitigate risk: unless Article 13 simplified due diligence applies, document Article 10 risk assessment and Article 11 mitigation before placing on the market or exporting when risk is not negligible.
  • Prepare system operations: register required users, submit due diligence statements or simplified declarations where applicable, capture identifiers, and communicate reference numbers or declaration identifiers downstream.
  • Update country-risk logic: use the applicable official Article 29 implementing act, retain the classification checked, and revise due diligence procedures when that official classification changes.
Primary sources

References and citations

Commission Implementing Regulation (EU) 2025/1093 on country risk
eur-lex.europa.eu3 citations
Referenced sections
  • Binding source for the current low-, high-, and standard-risk country classification.
  • Article 1 and the Annex establish the current low- and high-risk lists and retain standard risk for countries not listed.
  • Provides the current country classifications used with Articles 13 and 29.
"A standard level shall be maintained for all countries not listed in the Annex."
More quoted passages
"The countries that present a low, or high risk, shall be those listed in the Annex."
Regulation (EU) 2023/1115 key due diligence articles
eur-lex.europa.eu3 citations
Referenced sections
  • Articles 3 to 5, 8, and 38 support the market conditions, role-specific statement and information duties, and the two application cohorts.
  • Articles 4, 4a, 5, 13, 29, and 33 support simplified due diligence, submissions, identifiers, registrations, and recordkeeping.
  • Articles 8 to 13 and 38 support the evidence sequence and the dates by which it must operate.
"Relevant commodities and relevant products shall not be placed or made available on the market or exported, unless all the following conditions are fulfilled"
More quoted passages
"operators shall not be required to fulfil the obligations under Articles 10 and 11"
"Prior to placing relevant products on the market or exporting them, operators shall exercise due diligence"
Consolidated Regulation (EU) 2023/1115 on deforestation-free products
eur-lex.europa.eu2 citations
Referenced sections
  • Official consolidated text reflecting the binding Regulation and amendments on application cohorts, the EUTR transition, due diligence, simplified declarations, downstream information, and records.
  • Articles 37 and 38 support the 30 December 2026 and 30 June 2027 application cohorts, the EUTR-product exception, and the timber transition through 31 December 2029.
"Except as regards the products covered by the Annex to Regulation (EU) No 995/2010"
More quoted passages
"Articles 3 to 13, Articles 16 to 24 and Articles 26, 31 and 32 shall apply from 30 December 2026."
European Commission EUDR overview
environment.ec.europa.eu2 citations
Referenced sections
  • Commission overview confirming application cohorts and the 4 December 2024 information-system launch.
  • Confirms the three public-facing application cohorts and the information system launch date.
"Micro and small operators already covered by the EU Timber Regulation (EUTR): 30 December 2026."
More quoted passages
"The Information System as set out in Art. 33 of the Regulation was launched on 4 December 2024."

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