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 or broker that they will submit the due diligence statement (DDS) or the simplified declaration (SD) on your behalf. This should be recorded in the timber sales agreement or brokerage agreement. You may also submit the declaration yourself if you wish.
• 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.

These are tips from the Finnish Food Authority’s EUDR specialists based on the information currently available (June 2026).

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) or simplified declaration (SD) 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 or SD identifier 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 or SD. A sawmill purchasing the timber receives the DDS reference number or SD identifier but is no longer required to forward DDS reference numbers or SD identifiers 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 5, 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) or simplified declaration (SD) must be submitted for timber resulting from such felling, and the DDS reference number or SD identifier 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.

See: Domestic production and further processing - Finnish Food Authority

According to the Ministry of Agriculture and Forestry's new policy guidance (June 2026), farms engaged in direct sales are no longer considered operators within the meaning of the Regulation. As a result, the obligation to submit a due diligence statement (DDS) has been removed.

If a cattle farm engaged in direct sales that falls within the size category of a micro or small enterprise has calves born on the holding, the holding is considered a micro or small primary operator. In such cases, the Finnish Food Authority will submit the information required for a simplified declaration to the EUDR Information System on behalf of the holding. The holding will receive information from the Finnish Food Authority on the identifier of the simplified declaration.

The identifier must be passed on to the purchaser of the animals. The identifier is not animal-specific, and therefore, as long as the identifier remains unchanged, communicating it once to the next company in the supply chain is sufficient. The declaration identifier does not need to be provided to consumer customers.

The Finnish Food Authority is planning the practical arrangements for communicating this information and will provide more detailed guidance before the Regulation becomes applicable.

Other required measures:

• Comply with the applicable sector-specific legislation, as before.
• Please note that the harvesting of primary forests is, as a rule, contrary to the EUDR.
• Converting forest land to agricultural use causes deforestation within the meaning of the Regulation.

Farms engaged in direct sales where no new calves are born are, under the EUDR, either downstream operators or traders in the supply chain. More information on their obligations is available on the Domestic production and further processing page.

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.

If a product has already been placed on the market once, due diligence has already been carried out for that product. A new due diligence statement (DDS) is not submitted when the product is exported. The reference number of the DDS originally submitted for the product must be indicated in the customs declaration (if the exporter is an operator), or the identifier of the simplified declaration (if the exporter is a micro or small primary operator), or an appropriate customs code must be used (if the exporter is a downstream operator).

See FAQ v5, 5.6.1.

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. 

The updated guidance documents (FAQ and Guidance) published by the Commission at the beginning of May do not address this issue. The draft delegated regulation clarifies, in the case of rubber, that the Regulation would apply specifically to Hevea brasiliensis rubber and not to other types of rubber. Consequently, our interpretation is that the relevant products listed under rubber in Annex I to the Regulation that contain Hevea brasiliensis rubber fall within the scope of the obligations. In other words, due diligence should be exercised with regard to Hevea brasiliensis rubber regardless of its proportion in the product.

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.

As a rule, a simplified declaration is a one-time declaration. The information provided in the declaration must be updated if significant changes occur after the declaration has been submitted. Significant changes may include, for example, the consolidation of properties or the commencement of production of entirely new commodities. For example, the estimated annual quantity that was declared on a one-time basis and that is intended to be placed on the market or exported does not need to be updated.

Read more in FAQ v5, Question 3.27.

The EUDR does not prescribe a specific method for forwarding the DDS reference number or the SD identifie. The format can therefore be chosen freely. The reference number or the identifier 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.

Only the first entity placing the product on the market submits a due diligence statement (DDS) or a simplified declaration. After that, no new due diligence statements are submitted further along the supply chain.

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 retain for five years the reference number received from the importer, but you are not required to provide the reference number further down the supply chain or to submit a new due diligence statement (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. The company receives the DDS reference numbers or simplified declaration identifiers relating to the products if the supplier of the products is an operator within the meaning of the Regulation. These details must be retained, but they do not need to be passed on further down the supply chain.

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 Finnish Food Authority's interpretation, a single rubber seal, for example, may be considered to be for the company's own use when the seal is installed as part of the service provided. Accordingly, such activity would not fall within the scope of the EUDR where the seal is purchased from the EU internal market and the value of the product concerned is negligible in relation to the value of the service.