Frequently asked questions about the EUDR

The EUDR will apply from 30 December 2026. For micro and small enterprises, the transitional period will continue until 29 June 2027.

Please note: the extended transitional period does not apply to products covered by the current EU Timber Regulation (EUTR).

Land spanning more than 0,5 hectares with trees higher than five metres and a canopy cover of more than 10%, or trees able to reach those thresholds in situ, excluding land that is predominantly under agricultural or urban land use. 

An operator means a natural or legal person who, in the course of a commercial activity, places relevant products on the market or exports them. 

A trader means any person in the supply chain other than an operator who, in the course of a commercial activity, places relevant products available on the market. 

Placing on the market means making a relevant commodity or relevant product listed in Annex I to the EUDR available on the Union market for the first time. 

The marking ‘ex’ derives from the word extract. It indicates that within a given group of commodity codes, the EUDR applies only to certain products and not all products under that group.

Example 1: Code 9401 may include seats made from materials other than wood, but only wooden seats are subject to the requirements of the EUDR.

Example 2: Code 1602 50 may include products other than beef products, but only products made from cattle are subject to the EUDR. Bison meat sold under the same code is therefore not within the scope of the EUDR.

Placing on the market refers to the first time a product is made available on the EU market. This includes a situation in which a product is imported into the EU from a third country or manufactured within the EU and placed on the market for the first time.

In the context of the EUDR, making available on the market refers to a situation, for example, in which a product or commodity has already been placed on the EU market once and is subsequently traded within the EU.

See Article 2(16) and (18) of the EUDR.

Company size is determined based on the balance sheet total, net turnover and number of employees.

For example, a company is considered a large undertaking if it exceeds at least two of the following three criteria on the balance sheet date:

• balance sheet total: EUR 25,000,000
• net turnover: EUR 50,000,000
• average number of employees during the financial year: 250

A company is considered a small undertaking if it exceeds no more than one of the following three criteria on the balance sheet date:

• balance sheet total: EUR 7,500,000
• net turnover: EUR 15,000,000
• average number of employees during the financial year: 50

See also the Commission’s FAQ, Implementation of the EU Deforestation Regulation, Version 4, question 3.10, and the Accounting Act, Chapter 1, sections 4a–4c.

The company size and role are determined separately for each business ID. In this case, the obligations applicable to SMEs apply.

See also the Commission’s FAQ, Implementation of the EU Deforestation Regulation, Version 4, question 3.10, and the Accounting Act, Chapter 1, sections 4a–4c.

The conversion of forest to agricultural use constitutes deforestation within the meaning of the EUDR. The felling of forests to create pasture for any type of livestock or for cultivation constitutes deforestation. Timber obtained from such deforestation is not marketable under the Regulation and may only be used for own consumption. 

Commodities produced on deforested land are subject to the obligations of the EUDR if the commodity is listed in Annex I. For example, cattle or soya produced on deforested land are not marketable. By contrast, sheep, forage crops or potatoes produced on such land are marketable.

Declaration in excess refers to a situation in which a single due diligence statement (DDS) covers a broad set of land plots, even though the products concerned were produced only on part of those plots. This is permitted under the conditions described in the Commission’s FAQ, and the same approach may also be applied domestically.

For more information, see the Commission’s FAQ, question 1.18.

In the case of standing sales, the buyer of the timber or the intermediary organisation is responsible for compliance with the obligations under the EUDR. The forest owner remains responsible for complying with the Finnish Forest Act.

In the case of sales at delivered price and delivery sales:

• Agree with the timber buyer/intermediary that they will submit the due diligence statement (DDS) on your behalf. Record this in the timber sales agreement or intermediation agreement.
• Retain the forest use notification, the measurement document, and the timber sales or intermediation agreement for yourself.
• Continue to comply with the Forest Act as before.
• Note that, as a rule, the cutting down of primary forests is in violation of the EUDR.

In the case of standing sales, the buyer of the timber is considered the operator within the meaning of the EUDR.

If the timber is harvested for own use and no forest use notification is required, the EUDR does not impose obligations.

If the timber is intended for sale and no forest use notification is required, legality can be demonstrated by a landscape work permit, building permit, or another equivalent document showing that a forest use notification is not required. Also remember to retain the measurement document and the timber sales or intermediation agreement.

A due diligence statement (DDS) must be submitted for the timber in accordance with the EUDR, including geolocation data for the felling area. 

By-products such as wood particles and sawdust fall within the scope of the EUDR. Please note that following the amending Regulation of December 2025, certain traceability requirements have been eased. The obligation to pass on the due diligence statement (DDS) reference number only applies to the first transaction after placing the product on the market. For example, the buyer of standing timber is the entity placing the timber on the market and submits the DDS. A sawmill purchasing the timber receives the DDS reference number but is no longer required to forward DDS reference numbers with its own products.

The operator placing the product on the market may apply a mass balance approach (e.g. First-In-First-Out, FIFO). There is no obligation of physical separation, meaning that such methods may also be used for sawdust. The use of mass balance requires that all incoming material is compliant with the EUDR.

Yes. Provided that the time limit for regeneration under the Forest Act has not yet expired, responsibility for regeneration within the legally required timeframe transfers to the new owner, along with other statutory obligations. If the new owner decides to change the form of land use of the property, they must submit a forest use notification to the Forest Centre indicating the new land use purpose (see also the Commission’s FAQ, Version 4, question 4.8). If products covered by the EUDR are produced on land cleared from forest, such products are not compliant with the Regulation, and may not be placed on the EU market.

Among other provisions, the authorities are guided by Article 24 of the EUDR, which requires that measures must be appropriate and proportionate. The EU principle of proportionality must also be considered. It is difficult to give a precise answer, but as a rule, such withdrawal would apply to the quantity placed on the market in non-compliance and not to the entire larger quantity. Any additional sanctions imposed on the operator depend on the nature of the violation and the applicable legislation, such as environmental criminal law.

Under the EUDR, deforestation refers to the conversion of forest to agricultural use. The felling of forest for infrastructure purposes does not constitute deforestation within the meaning of the Regulation. However, a due diligence statement (DDS) must be submitted for timber resulting from such felling, and the DDS reference number must be provided to the timber buyer. The documentation related to the land use change must also be retained.

The conversion of forest to agricultural use constitutes deforestation within the meaning of the EUDR. The felling of forests to create pasture for any type of livestock or for cultivation constitutes deforestation. Timber obtained from such deforestation is not marketable under the Regulation and may only be used for own consumption. 

Commodities produced on deforested land are subject to the obligations of the EUDR if the commodity is listed in Annex I. For example, cattle or soya produced on deforested land are not marketable. By contrast, sheep, forage crops or potatoes produced on such land are marketable.

The use of mass balance is permitted when dealing with raw materials or products that have already been placed on the EU market. For example, several containers of raw rubber may be imported and mixed in a silo after import. If all the material placed in the silo has already met the requirements of the EUDR, all the material leaving the silo is likewise compliant.

The FIFO (First-In-First-Out) principle may be useful when forwarding due diligence statement (DDS) reference numbers, for example. Example: An importer has 200 units of goods in stock covered by three DDS reference numbers: 30, 70 and 100 units (in total 200 units). The importer sells 80 units and provides the buyer with the first two DDS reference numbers (for 30 and 70 units). When subsequently selling 100 units, the importer provides the buyer with the second and third DDS reference numbers (for 70 and 100 units). After this, 20 units remain under the final DDS reference number.

According to the national policy guideline, live cattle are not considered to be placed on the market in Finland when they are part of domestic contract production.

If the producer delivers cattle to a slaughterhouse, which then returns the beef to the producer for sale to consumers, the farm seller is considered an operator who makes the product available on the market for the first time when it is sold directly to consumers. 

If cattle are slaughtered on the production farm and the beef is then sold to consumers, the farm seller is likewise considered an operator who makes the product available on the market for the first time when it is sold directly to consumers. 

• Agree with the slaughterhouse that it will submit the due diligence statement (DDS) on your behalf. Record this in the agreement.
• Ensure that the information in the cattle register and the register of animal establishments is correct and up to date.
• Continue to comply with sector-specific legislation as before.
• Note that the cutting down of forest for cattle farming is, as a rule, in violation of the EUDR.
• Please also note that calves born before 29 June 2023 are not within the scope of the EUDR (see the Commission’s FAQ, question 1.25).

Clarification by the Finnish Food Authority (20 October 2025):

• A cattle farm engaged in direct sales fulfils the legality requirements of the EUDR by ensuring that:
  • Information in the cattle register is up to date, and all animals are properly identified.
  • The food supply chain information required by legislation has been delivered from the farm to the slaughterhouse, including the number and identification of the animals. The information must be retained for five years.
  • Settlement documents have been prepared with the slaughterhouse for each slaughter batch and are retained for five years.
• The geolocation information requirement is fulfilled by:
  • If all animals are born on the farm, providing the coordinates corresponding to the address related to the farm’s code of holding.
  • If calves are purchased from other farms, providing the coordinates related to each supplying farm’s code of holding. It is not necessary to collect geolocation information for each individual animal.
  • Collecting the geographic coordinates of the farm in question and of any farms supplying calves.
  • Providing this information to the party submitting the due diligence statement (DDS).
  • Updating the information at least once a year.
• The requirement of a negligible risk of deforestation is fulfilled by:
  • Relying on the Commission’s Country Classification List, as Finland is classified as a low-risk country of origin.
• If you submit the due diligence statement (DDS) yourself:
  • Register in the EUDR Information System (see instructions here).
  • Collect the above-mentioned information and record it in the system.

These clarifications have been issued by the Finnish Food Authority and apply to the initial phase of implementation. Further clarifications will be made as necessary based on implementation experience.

As a general rule, cattle may not graze on land that has been cleared from forest after 31 December 2020 if cattle or products derived from cattle (listed in Annex I) are to be placed on the market after the EUDR enters into force.

According to the Finnish Food Authority’s interpretation, deforestation within the meaning of the EUDR would not be considered to have occurred in the exceptional case in which a forest use notification was submitted before 2021, and it indicated a change of the form of land use to agricultural use.

Feed may also be produced on such land if the product concerned is not listed in Annex I to the EUDR, and such feed may be used for feeding cattle.

For more information, see Ministry of Agriculture and Forestry memorandum of 17 January 2025 (in Finnish) and the Commission’s FAQ, Version 4, question 1.26.1.

The conversion of forest to agricultural use constitutes deforestation within the meaning of the EUDR. The felling of forests to create pasture for any type of livestock or for cultivation constitutes deforestation. Timber obtained from such deforestation is not marketable under the Regulation and may only be used for own consumption. 

Commodities produced on deforested land are subject to the obligations of the EUDR if the commodity is listed in Annex I. For example, cattle or soya produced on deforested land are not marketable. By contrast, sheep, forage crops or potatoes produced on such land are marketable.

The use of mass balance is permitted when dealing with raw materials or products that have already been placed on the EU market. For example, several containers of raw rubber may be imported and mixed in a silo after import. If all the material placed in the silo has already met the requirements of the EUDR, all the material leaving the silo is likewise compliant.

The FIFO (First-In-First-Out) principle may be useful when forwarding due diligence statement (DDS) reference numbers, for example. Example: An importer has 200 units of goods in stock covered by three DDS reference numbers: 30, 70 and 100 units (in total 200 units). The importer sells 80 units and provides the buyer with the first two DDS reference numbers (for 30 and 70 units). When subsequently selling 100 units, the importer provides the buyer with the second and third DDS reference numbers (for 70 and 100 units). After this, 20 units remain under the final DDS reference number.

As a general rule, no. If an SME exporter has a DDS reference number linked to the batch, the exporter may use this reference number (or numbers) in the customs declaration. Among other documents, this issue is addressed in the Commission’s FAQ.

Annex I to the EUDR lists the commodity codes (HS codes) that fall within the scope of the obligations. Finnish Customs is responsible for the classification of the goods, which determines whether the goods fall within the scope of the Regulation. For example, if Customs classifies the product as metal furniture, it does not fall within the scope of the EUDR, even if it has wooden legs.

Finnish Customs is the authority responsible for matters related to commodity codes. 

Read more about commodity codes and contact the Customs customer services if necessary.

A key concept under the EUDR is placing on the market. In the context of imports, placing on the market occurs when Customs releases the goods for free circulation, in other words, when customs clearance is approved. The importer is therefore subject to the obligations under the Regulation, even if the products are subsequently delivered outside the EU. 

This matter is currently under discussion at EU level, and the Commission may issue further guidance. The Commission’s FAQ, Version 4, question 1.3, addresses composite products and is related to this issue, but it does not take a position on percentages. 

This is the situation in February 2026, and this answer will be updated.

The amending Regulation (of December 2025) introduced certain relaxations, including in the traceability obligations. This will also affect exports. An EU-wide discussion has not yet taken place, but according to the preliminary interpretation, new DDS statements will no longer need to be submitted in connection with exports. The obligation to indicate the DDS reference number in exports is expected to remain only for a very limited group of operators.

In the amending Regulation (EU) 2025/2650, the relevant provisions affecting exports include Article 1, points (1)(b) and (17).

This is the situation in February 2026, and this answer will be updated.

The quantity of imported products does not affect the obligations laid down in the Regulation. The full set of obligations therefore also applies to companies that only occasionally import EUDR products.

You are importing an EUDR product from outside the EU and are therefore subject to the obligations of an importer, including maintaining a due diligence (DD) system and submitting a due diligence statement (DDS). For more information, see the section on import obligations.

As you do not sell products that fall within the scope of the EUDR further, you are not required to forward the DDS reference number to your customers.

The use of mass balance is permitted when dealing with raw materials or products that have already been placed on the EU market. For example, several containers of raw rubber may be imported and mixed in a silo after import. If all the material placed in the silo has already met the requirements of the EUDR, all the material leaving the silo is likewise compliant.

The FIFO (First-In-First-Out) principle may be useful when forwarding due diligence statement (DDS) reference numbers, for example. Example: An importer has 200 units of goods in stock covered by three DDS reference numbers: 30, 70 and 100 units (in total 200 units). The importer sells 80 units and provides the buyer with the first two DDS reference numbers (for 30 and 70 units). When subsequently selling 100 units, the importer provides the buyer with the second and third DDS reference numbers (for 70 and 100 units). After this, 20 units remain under the final DDS reference number.

Due diligence statements can be submitted in machine-readable format. Questions related to the interfaces (APIs) of the EUDR Information System are handled by the Commission’s IT unit. Read more about the EUDR Information System.

Issues related to logging into the EUDR Information System – for example, due to a change of phone or the activation of two-factor authentication – are handled by the Commission (sante-traces@ec.europa.eu). 

A DDS does not need to be batch-specific. It may cover several batches of different relevant products. A DDS may be prepared up to one year in advance.

For more information, see the Commission’s FAQ, Version 4, question 5.19.

The EUDR does not prescribe a specific method for forwarding the DDS reference number. The format can therefore be chosen freely. The reference number may be included on an invoice, order confirmation or other documentation.

Both the DDS reference number and verification number may contain letters and numbers. The reference number may contain a maximum of 14 characters, and the verification number a maximum of 8 characters. 

If it is not yet known at the time of preparing the DDS whether the products will be sold on the internal market or exported, the DDS may be prepared for exporting the entire quantity. Documentation must be retained showing the quantities corresponding to internal market sales and exports.

For more information, see the Commission’s FAQ, Version 4, question 5.19 (5).

The DD system refers to a written description of the company’s procedures and measures by which the operator systematically ensures product compliance.

Read more about the DD system.

The operator must be able to present reliable, fact-based information that can be verified by the authorities, demonstrating that the production of the raw materials has not caused deforestation. The information must be based on appropriate documentation and, where necessary, geospatial data enabling the verification of the origin and production conditions of the raw materials. For example, deforestation-free status may be demonstrated by establishing the harvest location of the raw material, land use and the harvesting method prior to the time of harvest, as well as any land-use changes or related plans after harvest.

For more information, see the Commission’s FAQ, Version 4, question 1.20.

If a DDS has already been submitted for the product, an SME does not need to submit a new DDS. SMEs are also addressed in the Commission’s FAQ and on the Factsheet for SMEs website.

A DDS is submitted only when a product or raw material is placed on the market for the first time. For cocoa, the importer submits the DDS. You are required to request the DDS reference number from the importer but are not required to forward the reference number further or to submit a new DDS.

Products and raw materials already in stock may be sold after the Regulation becomes applicable, and no DDS is required for them, provided that it can be demonstrated that they were placed on the market before the date of application. 

For more information, see the Commission’s FAQ, Version 4, Chapter 9.

A company that purchases furniture covered by the EUDR within the EU and sells it in its own shops acts as a trader. Large traders must register in the EUDR Information System. Traders of all sizes must collect and retain information about their suppliers. If products are purchased from an operator (e.g. an importer), information related to due diligence statements or simplified declaration identifiers must be collected and retained. When products are sold directly to customers from a shop, no information under the EUDR needs to be forwarded further. 

Read more about domestic and intra-community trade.

You purchase coffee within the EU and manufacture products (HS 2101) that are not listed in Annex I to the EUDR. You are not subject to obligations under the Regulation, as you do not place on the market, make available on the market or export products covered by the Regulation.

According to the current interpretation (February 2026), a single rubber seal may be considered to fall within the company’s own use when it is installed as part of a service. A DDS is therefore not required, as the value of the product concerned is negligible in relation to the value of the service provided.