Regulation (EU) 2023/1115 · EUDR · Large operators 30 Dec 2026

Now every shipment names the ground it grew on.

Seven commodities, one cutoff: 31 December 2020. Every plot geolocated, every batch legal, every shipment covered by a Due Diligence Statement before it clears customs.

The problem

Born at the plot. Owed at the border.

A bag of cocoa passes through a farmer, a cooperative and an exporter before an EU importer ever sees it. The proof the law wants, the exact plot it grew on and that the land was neither cleared after 31 December 2020 nor farmed against local law, is born at the first hand and has to survive every one after. Break the relay anywhere and the importer carries the fine.

The importer files, but the proof is born at the plot. Coordinates, land title, harvest records: lose any of it at a handoff and the container stops at the border.

7commodities that now need a geolocated, legal origin
4%of EU-wide turnover, the floor for a non-compliance fine
10M haof forest lost a year; about a tenth traced to EU demand
0mixing tolerated. One unverified bag fails the whole container

Trust us moved containers into Europe for decades. A supplier's word, a scheme logo, done. Now the law says show us the ground the goods grew on.

EUDR · Regulation (EU) 2023/1115 · Article 3
The flow

Collect the plots once. File every shipment after.

Everything the law asks is a data pipeline wearing a legal costume. Bindu builds it in seven moves.

01 · Collect

Collect every plot, once.

Capture each parcel on a map or as a GeoJSON upload: coordinates, harvest window, the land document behind it. Once, not every shipment.

GPS pointGeoJSON polygonland titleharvest window
02 · Validate

Check the geometry before the satellite does.

Bindu validates every plot against the current rules: six decimals for a point, real vertices for a polygon over 4 hectares, and no parcel left out.

6-decimal pointpolygon > 4 haevery parcelno sampling
03 · Screen

Screen the origin's risk tier.

Article 29 sorts every country into low, standard or high risk, and the tier sets how much due diligence you owe. Bindu screens it per batch.

Art 29 benchmarklow · standard · highrisk assessment
04 · Assemble

Assemble the Due Diligence Statement.

The Article 9 field list fills itself from the plots and the batch: CN code, weight, origin, geolocation, time range, supplier, the attestation.

CN codegeolocationArticle 9 fieldsattestation
05 · File

File it in TRACES. Keep the number.

Submit the statement to the EU Information System. It returns a reference number, the one thing customs actually checks.

TRACES DDSreference numberEU Information System
06 · Carry

Put the reference on the customs declaration.

The reference travels with the customs declaration. Customs cross-check it against the Information System, and the shipment is released.

on the declarationcustoms cross-checkreleased
07 · Archive

Archive the proof for five years.

Every plot, alert, filing and evidence pack lands in a hash-chained archive. Every actor in the chain carries the same five-year retention duty.

5-year retentionhash-chainedaudit vault
The scan

Not all origins are equal.

Article 29 sorts every country into three risk tiers, and the tier decides how much due diligence you owe and how often you get checked. Pick a tier. Watch what you owe change.

Low risk140 countries in scope
Low riskAll the EU, the US, China
Low riskCollect the data, file the DDS
Low riskNo risk assessment required
Low riskNo mitigation required
Low riskAbout 1% of operators checked
Standard riskAround 50 countries
Standard riskBrazil, Côte d'Ivoire, Indonesia
Standard riskFull risk assessment, every batch
Standard riskMitigation where risk is found
Standard riskNo simplified declaration
Standard riskAbout 3% of operators inspected
High risk4 countries
High riskBelarus, Myanmar, North Korea, Russia
High riskThe full due-diligence programme
High riskAt least 9% of operators checked
High riskAt least 9% of volumes checked
High riskShipments stopped and examined

The list is the country benchmarking of May 2025 (Implementing Regulation (EU) 2025/1093). Standard risk is the default, and it gets no simplified declaration.

Granularity

A point, a polygon, or a block.

Coordinates are the link between a real farm and the satellite that checks it. The rules are mechanical, and so are the failures.

Under 4 hectares

A point

One latitude/longitude pair, six decimals or more. Fewer decimals and the EU system cannot resolve the plot, so the statement gets challenged.

Over 4 hectares

A polygon

Enough vertices to trace the real perimeter, as GeoJSON. A single point on a big farm lets the scan radius swallow neighbouring forest.

The hard rule

Zero mixing

Mass balance is not accepted. One bag of unknown origin contaminates the whole container. Verified and unverified lots stay apart, physically and on paper.

Geolocation is required for every parcel that fed the batch. No representative sample, no materiality threshold. Cattle is the one case a single point never satisfies.

The calendar

The dates that actually apply.

The regulation was postponed twice and simplified once. Ignore the 2024 and early-2025 deadlines you may have read. These are the ones in force, and the deadline is close.

31 Dec 2020The cutoff

The cutoff. Land cleared after this date is non-compliant, whether or not the clearing was legal locally, and it does not reset when the land changes hands.

29 Jun 2023

Regulation (EU) 2023/1115 enters into force, replacing the old Timber Regulation and starting the compliance clock.

22 May 2025

The first country benchmarking list is published (Implementing Regulation (EU) 2025/1093), sorting origins into low, standard and high risk.

23 Dec 2025

Regulation (EU) 2025/2650: a second postponement plus real simplification. Annual statements, printed matter dropped from scope, downstream operators reuse the upstream reference number.

30 Dec 2026The deadline

Application date for large and medium operators. The real deadline, and it is close.

30 Jun 2027

Application date for micro and small operators.

The loop

Satellites see loss. They can't see why.

The most misunderstood part of the law. From orbit, routine farm work looks like deforestation, and a compliant farm can still trip an alert.

Shade pruning, stumping for regeneration, a polygon drawn too close to the forest edge, tropical cloud cover: all of it reads as tree-cover loss. An alert is not a verdict. Most die at a desk, once the geometry is fixed or pre-2020 records are attached. The supplier who can prove it becomes the low-risk partner every European buyer is now hunting for.

  • shade pruning
  • stumping
  • geometry error
  • cloud cover
  • adjacent forest
  • pre-2020 crop
How it's built

How Bindu files it.

Plots collected once, every batch after it mechanical, the whole trail archived. That is the pipeline. Pick a piece to see the job it does.

Collect once

Plot capture

A map or a GeoJSON upload takes each parcel's coordinates, harvest window and land document. Collected once, reused on every shipment after.

  • Map + GeoJSON
  • Land documents
  • Reused per batch
The upside

Be the supplier Europe can't say no to.

Get the plots right once and every shipment after is mechanical. Bindu validates each batch, builds the GeoJSON and the DDS, and keeps the five-year vault, updating your filings when the rules change again. What it buys you is the low-risk supplier every European buyer is now hunting for.

Plots oncecollect once, file every shipment after
Zero mixingverified and unverified lots kept apart
5-year vaulthash-chained evidence, every actor
Rules trackedfilings updated when the law shifts
The moatbecome the low-risk supplier buyers hunt for

The detail · EUDR

The EU Deforestation Regulation (EUDR), Regulation (EU) 2023/1115, bans seven commodities and their derived products from the EU market unless they are deforestation-free, produced legally in the origin country, and covered by a Due Diligence Statement. The cut-off is 31 December 2020: goods linked to land deforested after that date cannot be sold in or exported from the EU.

Key dates — application set by Regulation (EU) 2025/2650, the second postponement of the original 2024 deadline.

DateWhat happens
31 Dec 2020Deforestation cut-off date. Production on land cleared after this date is non-compliant.
30 Dec 2026Obligations apply to large and medium operators and traders.
30 Jun 2027Obligations apply to natural persons and micro and small enterprises (established by 31 Dec 2024).

The seven covered commodities

  • Cattle
  • Cocoa
  • Coffee
  • Oil palm
  • Rubber
  • Soya
  • Wood

Who has to comply with the EUDR?

Any operator that places one of the seven commodities (or a product derived from them — leather, chocolate, furniture, paper, tyres, printed books, and more) on the EU market for the first time, and any trader that makes it available further down the chain. Importers are operators. The obligation follows the goods, not the sector, so a small importer of coffee, cocoa, or rubber is squarely in scope — see the guide to all seven commodities.

Company size changes the timing and the depth of checks, not the principle: large and medium businesses start first, micro and small enterprises later, and SMEs may rely on due diligence already carried out upstream rather than repeating it. Not sure a given product is in scope? The EUDR coverage checker answers it in a few clicks; for the exact application dates, see the EUDR deadlines.

What is a Due Diligence Statement (DDS)?

Before covered goods clear customs, the operator files a Due Diligence Statement in the EU's TRACES information system. The DDS confirms that due diligence was carried out and that the risk of deforestation or illegality is negligible. Submitting it returns a DDS reference number, which is quoted in the customs declaration. No reference number, no clearance.

Due diligence has three steps: collect the required information (Article 9), assess the risk, and — where risk is more than negligible — mitigate it until it is. The information, the risk assessment, and the mitigation must be kept for five years.

What geolocation data does the EUDR require?

For every plot of land where the commodity was produced, you provide the geographic coordinates (latitude and longitude to at least six decimal places). Plots under four hectares can be given as a single point; plots of four hectares or more must be a polygon. For cattle, you geolocate every establishment where the animals were kept. Coordinates are supplied as GeoJSON in the WGS84 reference system and tie each batch back to specific ground.

How does country benchmarking work?

The Commission classifies producing countries (and regions) as low, standard, or high risk. The tier sets how hard authorities check you: enforcement checks cover a defined share of operators in each tier, with the highest rate for high-risk origins. Sourcing from a low-risk country unlocks a lighter simplified due diligence — you still collect the information and file the DDS, but the full risk-assessment and mitigation steps are relaxed.

What are the penalties for non-compliance?

Penalties are set by member states but have an EU floor: fines of at least 4% of the operator's total annual EU-wide turnover, confiscation of the goods and of the revenues from them, and temporary exclusion from public procurement and public funding (Article 25). Non-compliant goods are also kept off the market.

Sources

Last reviewed 11 July 2026