EUDR Scope: Who Must Comply with the Regulation?

Who must comply with EUDR?

Regulation (EU) 2023/1115 applies to all entities that place on the EU market, export from the EU, or make available on the internal market products derived from the seven relevant commodities. Obligations vary depending on the economic role and the size of the enterprise.

Operators

An operator is any natural or legal person who, in the course of a commercial activity, places relevant products on the EU market for the first time or exports them from the EU. This includes:

• Importers introducing relevant products onto the European market
• EU-based producers placing products on the market (e.g. a furniture manufacturer using timber)
• Exporters sending relevant products outside the EU

Operators have the strictest obligations: they must carry out full due diligence, collect geolocation coordinates, and submit a due diligence statement in the EU information system.

Traders

A trader is any person in the supply chain, other than the operator, who makes relevant products available on the market in the course of a commercial activity. Traders are required to:

• Keep records of suppliers and commercial customers for at least 5 years
• Verify the existence of a valid due diligence statement
• Notify competent authorities if they identify non-compliance

Large operators vs. SMEs

The regulation makes an important distinction between large enterprises and SMEs (small and medium-sized enterprises):

• Large and medium operators and traders: Compliance deadline of 30 December 2026 (also applies to micro/small operators handling timber). Full due diligence is mandatory for operators
• Micro and small operators (non-timber): Extended deadline until 30 June 2027. Primary operators producing in low-risk countries may file a simplified one-time declaration. Downstream companies file no statement — only the first downstream buyer retains upstream reference numbers

Exemptions

The regulation does not apply to products in transit through the EU (not placed on the market). Products manufactured or obtained before the regulation's entry into force may be placed on the market if they were legally introduced onto the market previously.

Products from countries classified as low risk benefit from a simplified due diligence procedure, but are not fully exempt from the regulation's requirements.

Supply chain responsibility

Each entity in the supply chain is responsible for its own compliance. A trader cannot invoke the fact that the operator has already submitted a due diligence statement to exempt itself from its own verification obligations.

For details on the due diligence process, see the due diligence guide. For exact deadlines and legal analysis, visit the dedicated pages.