Quick Tips for Logistics Professionals
A new European regulation comes into force at the end of 2026, impacting imports of products that play a role in deforestation and forest degradation worldwide.
- Which products are concerned? All those containing wood, soy, palm oil, coffee, cocoa, livestock or rubber, including their many derivatives.
- What are the obligations? Operators will have to collect data on the origin and traceability of their products (geolocation, risk assessment), then make a prior declaration via TRACES.
- What’s the timetable? The regulation will apply from December 2026 for large companies, and from June 2027 for SMEs.
- What are the risks of non-compliance? Penalties can be as high as 4% of sales, with confiscation and exclusion from public contracts.
Why prepare now? Because these rules affect your logistics flows, their documentation, coordination with your suppliers, and ultimately your customs transits.
The European Union is tightening the rules to exclude from the market products that contribute to deforestation and forest degradation. Regulation (EU) 2023/1115, known as RDUE, imposes new customs, traceability and compliance obligations from 2026. Here’s how to prepare.
Understanding the EUDR in 5 points
What is the RDUE?
Regulation (EU) 2023/1115 against deforestation and forest degradation, adopted in May 2023, aims to ban, from 2026/2027, the import or export of products linked to deforestation or forest degradation since December 31, 2020. It covers 7 product categories: livestock, cocoa, coffee, oil palm products, rubber, soy and wood.
Background & objectives
According to the FAO, deforestation is responsible for 11% of greenhouse gas emissions. Faced with accelerating deforestation, accelerating climate deregulation and rising environmental demands, the European Union intends to make international trade a key instrument of its climate policy.
The aim of the EUDR is to guarantee “zero deforestation” consumption in the EU, by reinforcing the responsibility of economic operators.
The principle of due diligence
The central feature of this regulation is “due diligence”, a process requiring operators to attest to the conformity of the products concerned before they are placed on the market. They will have to ensure the collection of accurate information (including the geolocation of plots), the assessment and, if necessary, the mitigation of environmental risks, in order to make a declaration of due diligence (DDR), required when goods are imported and marketed.
Application timetable
The reference date for the scheme is December 31, 2020: only products made on land that has not undergone deforestation or forest degradation after this date will be allowed on the EU market. The original timetable for application of the EUDR has been modified:
- December 30, 2026 for major companies and operators.
- June 30, 2027 for SMEs.
Penalties
In the event of non-compliance, companies face heavy penalties that can include fines of up to 4% of their EU sales, confiscation of the offending goods or the profits from their sale, and temporary exclusion from European public procurement contracts.
The regulation acts as an “ecological passport” for goods: without traceability documents and proof of non-deforestation, the product is blocked at the border or withdrawn from the market, resulting in immediate financial losses and heavy legal penalties.
Which operators and products are affected by the EUDR?
Companies, traders and freight forwarders
- Due diligence applies to all operators and traders involved in bringing a product to market. Even if you are an SME, you are subject to this duty of care.
- However, SMEs are exempt from this obligation if the product has already been declared; in other words, if they have already placed the product on the market in the past: they will benefit from a simplified single declaration and will simply need to transmit their unique identifier to their customers.
- Retailers or manufacturers using materials already imported into the EU will no longer be obliged to submit an RFI themselves, but will have to collect and transmit the identification numbers of upstream operators.
- Logistics operators are not directly subject to the EUDR, but must exercise a duty of vigilance, i.e. check that compliance documents are supplied, particularly for wooden packaging.
Products covered by the EU RD and their HS codes
The RDUE targets 7 categories of raw materials: livestock, cocoa, coffee, palm oil, rubber, soya, wood, as well as their numerous derivatives listed in appendix 1. Here are a few examples of goods subject to these regulations:
- Cattle (in HS codes 0201 to 4107): live, meat, offal and liver, hides and skins
- Cocoa (in HS codes 1801 to 1806): beans, shells, paste, waste, butter, powder without sugar or sweeteners, chocolate
- Coffee (in HS codes 0901)
- Oil palm (in HS codes 1207, 1511 to 1513, 2306 to 2915, 3823): nuts, oils, residues of palm nuts or kernels
- Rubber (in HS codes 4001 to 4017): natural, mixed, yarns and cords, plates, belts, tires, clothing
- Soya (in HS codes 1201, 1208 and 2304): beans, meal, oil, oilcake and other solid residues
- Wood (in HS codes 4401 to 4421 and 49, 9401 to 9406): firewood, coal, rough, plywood, joinery, crates.
Please check your merchandise on a case-by-case basis in Appendix 1.
There are no value or volume thresholds.
Any product containing one of these raw materials may be affected.
EXAMPLE: if you transport cattle fed on soya, you are subject to regulations (on the cattle + on its feed, in this case soya).
Special case of packaging :
Packaging is not subject to the RDUE when it is used solely to protect another good, such as pallets used for transport. On the other hand, they are subject to the regulation when they are themselves thesubject of a commercial exchange (such as new pallets, empty crates, or packaging sold separately) or if they are repaired with new wood. Thus, an already-used pallet repaired with new wood is subject to the regulations. The same applies to wooden boxes, crates, cylinders and similar packaging; single pallets, box pallets and other wooden loading trays.
Other special cases
- 100% recycled & waste products are not subject to RDUE
- Goods undertemporary admission are not released for free circulation, and are therefore not subject to the regulations; however, a duty of vigilance does apply.
- Reusable packaging marked “exempt” is no longer subject to this requirement if it has already been used, but this is a complex issue to track, and we are awaiting clarification on this point.
The EUDR in practice: 4 steps
Implementing the EUDR requires preparation in several stages:
1. Determine whether your goods are subject to the EUDR
Check to see if your products fall under Annex I of the regulation. Please note: this is not an exhaustive list. You should check your goods on a case-by-case basis.
If in doubt, we recommend that you request a BTI (Binding Tariff Information) from customs to secure the classification of your goods.
2. Assessing and mitigating provenance risks
Operators must check whether their products present a risk of non-compliance with the EUDR. This is based on analysis of provenance (country, region, plot) and compliance with local laws. In case of doubt or risk, corrective measures are expected: verification of data, audits, or strict separation of batches.
For products from low-risk countries, or for SMEs, simplifications are foreseen: lighter controls, and exemptions from certain obligations such as audits or the appointment of a compliance officer.
NB: see the European Commission’s list of low-risk countries.
3. Complete the Declaration of Due Diligence (DDR) in TRACES
Armed with the information gathered, operators must submit their Declaration of Due Diligence (DDR) to the European TRACES information system, including their EORI number, HS code, country of origin and product geolocation coordinates.
4. Completing the customs declaration
- Once the RDDR has been submitted and validated in the information system, the RDDR reference number can be referenced in the customs declaration for your goods.
See the RDUE guide published by French Customs. - For downstream operators, the verification number makes it possible to refer to declarations already made upstream in the supply chain.
- Important: Once the RFD reference number has been used in a customs declaration, it is no longer possible to modify or withdraw the RFD.
The WFD reference number can be compared to a digital key: without this key correctly inserted in your customs declaration, the “gateway” to the European market remains closed for the goods, as the customs system will not be able to confirm that the product complies with non-deforestation standards.1207,
