The preparation for compliance with the EU Deforestation-Free Regulation (EUDR) has entered a critical phase. According to the latest negotiation mandate of the EU Council in November 2025, it has put forward a proposal to extend the regulation's implementation timeline, covering 7 categories of regulated products and their derivatives including timber, coffee, cocoa, etc.
It should be clarified, however, that this proposal has not yet officially entered into force. Export enterprises should not ease their preparations on the pretext of policy adjustments, but still need to plan in advance based on existing information to smoothly access the EU market.
This article breaks down the key compliance points most concerned by exporters, avoids common misunderstandings, and clears green obstacles for product exports.
I. Core Understanding: DDS and Exporters' Responsibility Scope
The Due Diligence Statement (DDS) is the core compliance document under EUDR, used to prove that the product's production site has no deforestation/forest degradation after 2020, the production is legal, and due diligence has been completed.
For regulated products to enter the EU market, the direct placing entity (usually the EU downstream customer) must declare the DDS and obtain a registration number.
Domestic exporters do not need to declare the DDS directly, but they must assume key responsibilities: fully transmit compliance information to EU customers to assist them in completing the declaration.
If the information is delayed or incomplete, the product may be prohibited from entering the market.
II. Key Actions: What Compliance Information Must Exporters Transmit?
To assist EU customers in completing DDS declarations, exporters must prepare and transmit the following core compliance information in advance, ensuring it is true and complete:
Basic product information: Including HS code, product name (Latin name required for timber products), and net weight of exported products;
Deforestation-free certification: Accurate GPS coordinates of the production plot and satellite images of the production site—key evidence for verifying deforestation-free status;
Supply chain traceability materials: Raw material source information and supply chain transmission evidence to ensure full-chain traceability;
Legal production certification: Land ownership certificates, labor protection policy documents, etc., to confirm the compliance of production activities;
Risk-related materials: If the product is from a non-low-risk country, additional risk assessment reports and risk mitigation measures must be provided.
III. Common Pain Points: How to Address These Compliance Challenges?
What if upstream suppliers refuse to provide GPS coordinates of the production plot?
GPS coordinates are the core of deforestation-free verification; products without them will be prohibited from entering the EU market.
It is recommended to fully communicate the mandatory nature of EUDR compliance with upstream suppliers. By signing supplementary agreements or adjusting cooperation terms, ensure the acquisition of accurate coordinates to avoid export disruptions due to supply chain coordination issues.
When should compliance information be transmitted to downstream parties?
Regarding compliance timelines, the EU Council has proposed unified adjustments to EUDR's mandatory implementation timelines: the application date for medium and large operators is proposed to be postponed to December 30, 2026, and for micro and small operators to June 30, 2027. A core prerequisite, however, is that this timeline has not yet officially taken effect and is subject to final approval by the European Parliament and the EU Council. At this stage, enterprises still need to advance compliance preparations based on the original deadline to avoid delays caused by waiting for the policy to be finalized.
EU customers must complete DDS declarations before the product arrives at the port. Therefore, it is recommended to transmit complete compliance information 1-2 months in advance to reserve sufficient declaration time and avoid cargo detention.
Can low-priced or small-volume products be exempted?
Whether a product is regulated by EUDR has no relation to its price or volume. The core criterion is whether it falls under the 7 categories of goods listed in Annex 1 of the regulation (beef, coffee, cocoa, palm oil, soybeans, rubber, timber) and their derivatives.
Even small-batch products must meet compliance requirements if they are within the regulated scope.
Are wooden packaging materials regulated?
The criterion is whether the product is traded as an "independent commodity" in the EU market.
Packaging materials solely used to support, protect, or transport other products are not regulated by EUDR, even if their HS codes are in the regulated list;
If the packaging itself is circulated as a commodity, it must comply with EUDR requirements.
IV. Important Reference: How Does Country Risk Classification Affect Compliance?
The EU classifies trading partner countries into three risk levels: high, medium (standard), and low, with different compliance requirements for each level:
Low-risk countries (e.g., China): Products are eligible for simplified due diligence, with no need to provide additional risk assessments or mitigation measures;
Standard-risk countries (e.g., Indonesia, Malaysia): Complete risk assessments and mitigation measures must be conducted as required;
High-risk countries (e.g., Russia): Products face stricter inspections and frequent verifications, but they are not prohibited from export—more detailed due diligence requirements must be met.
Exporters can prepare targeted compliance materials based on the risk level of the raw material source country, avoiding compliance gaps caused by misjudgment of risk levels.
SKYCO2: Empowering Exporters to Efficiently Address EUDR Compliance
EUDR compliance involves information organization, supply chain coordination, policy interpretation, and other links, which enterprises may struggle to advance alone.
Based on EUDR rule interpretation and industry practice, SKYCO2 provides tailored compliance support:
Organize compliance information lists to meet EU verification standards;
Provide guidance on engaging upstream suppliers and clarify the path for obtaining key information;
Supply compliance material organization templates to improve information transmission efficiency;
Real-time tracking of policy developments, and synchronization of rule adjustments and response suggestions.
If your enterprise is troubled by EUDR compliance information transmission or supply chain coordination, or wishes to make advance preparations, please feel free to contact SKYCO2.
We will use pragmatic services to help you lay a solid compliance foundation, calmly address challenges, and firmly seize EU green trade opportunities.