EU Deforestation Regulation
European regulation prohibiting the placing on the EU market of products linked to deforestation after 31 December 2020, covering 7 commodities including leather. Regulation (EU) 2023/1115.
Context
EUDR (EU Deforestation Regulation) prohibits the placing on the EU market of products linked to deforestation after 31 December 2020. It applies to 7 core commodities and their derived products, including textile leather.
Regulatory origin
Regulation (EU) 2023/1115 of the European Parliament and of the Council of 31 May 2023, published in OJEU L 150 on 9 Jun 2023. It replaces Regulation (EU) 995/2010 (EUTR · timber-only).
The 7 covered commodities (Art. 1.1)
Cattle (including tanned leather).
Cocoa.
Coffee.
Oil palm.
Soy.
Wood (all forms).
Natural rubber.
Due Diligence Statement (DDS)
Art. 4 EUDR requires submitting a DDS for each product consignment, with sub-plot geolocation of the origin, evidence of legal production and full supply-chain traceability down to the plot of land.
Timeline
EUDR adopted
Regulation (EU) 2023/1115 published in OJEU L 150 on 9 Jun 2023.
Entry into force
20 days after publication.
Application postponement
Regulation (EU) 2024/3234 postpones application by 12 months due to implementation difficulties.
Wave 1 application
Large operators and traders apply the EUDR in full.
Wave 2 SMEs
Small and medium-sized operators apply the EUDR.
Applied case
A textile brand with a leather footwear line (10 per cent of the catalogue) prepares its EUDR compliance ahead of the application date of 30 Jun 2026 (SMEs).
Origin map: it identifies the 4 leather suppliers (Italy, Brazil, India) and requests sub-plot geolocation of the ranch of origin of the cattle.
For each consignment, it collects the DDS with GPS coordinates, evidence of no deforestation after 2020 and certification of local legal production.
It uploads the DDS to the European Commission's TRACES platform before each import.
Risk identified: 1 Brazilian supplier with an Amazon chain · replaced by a Uruguayan supplier with grasslands outside the Amazon biome.
Common mistakes
The EUDR does not apply to cotton as a direct textile fibre.
Cotton is in the annex, but its coverage is derived via its specific processed products. Pure textile fibre is not within the scope of the Regulation — always check the annex list.
The EUDR is not just labelling.
It is an operational system with a per-consignment declaration in TRACES and a prohibition on placing on the market if not complied with. It is not a voluntary label.
Saying "deforestation-free country" does not exempt you.
The EUDR requires plot-level geolocation with a georeferenced polygon for plots >4ha. A country-level declaration is not sufficient.
The EUDR does not overlap exactly with the CSDDD.
The CSDDD is cross-cutting due diligence. The EUDR is a specific obligation with an operational system (TRACES) and a prohibition on placing on the market. They are complementary regimes, not alternatives.
Frequently asked questions
What is the EUDR?
Regulation (EU) 2023/1115 on the making available on the Union market and the export from the Union of certain commodities and products associated with deforestation and forest degradation. Published in OJEU L 150 (9.6.2023, pp. 206-247) (CELEX 32023R1115). It prohibits the marketing of 7 commodities (including textile leather) that have contributed to deforestation after 31 Dec 2020.
Who does the EUDR apply to?
Any economic operator that places on the EU market or exports from the Union cattle, cocoa, coffee, oil palm, soy, wood, rubber and their derived products (ANNEX I). For textiles-footwear, tanned leather and leather articles are listed — it directly affects brands with a footwear/accessories line.
How is the EUDR complied with?
Under Arts. 4-9: (i) a geolocated due diligence statement in the Commission's TRACES system before placing the product on the market, (ii) a georeferenced polygon for plots >4 ha (country of origin is not accepted as sufficient), (iii) verification of no deforestation after 31 Dec 2020, (iv) compliance with the legality of the country of origin.
When does the EUDR come into force?
Operational application deferred to 30 Dec 2025 for large companies and 30 Jun 2026 for SMEs (Reg. EU 2024/3234 corrigendum). The Regulation formally entered into force on 29 Jun 2023, but the operational TRACES obligation is deferred.
What is the difference between the EUDR and the CSDDD?
The EUDR is a specific regime with an operational system (TRACES) and a prohibition on placing on the market for 7 specific commodities. The CSDDD is a cross-cutting due-diligence regime over the entire chain of activities covering human rights and the environment. They are complementary regimes — the EUDR does not exempt you from the CSDDD or vice versa.
What penalty is there for breaching the EUDR?
Under Art. 25: fines proportionate to the environmental damage caused and the economic benefit of the non-compliant activity, with a minimum of 4 per cent of the company's annual turnover in the EU. Additionally: confiscation of products, temporary prohibition on marketing, exclusion from public procurement and public funding.
Fuentes oficiales
- European Parliament · European Council · OJEU L of 9.6.202331 may 2023regulation
- European Commission · OJEU L of 30.12.20242024-2026regulation
- EUR-Lex · Publications Office of the European Union2025database
