Deforestation-free products. EUDR Guide 2025

5 September, 2025

Deforestation-free products. EUDR Guide 2025–2026

The European Union’s regulation on deforestation-free products (EUDR) requires that certain products can only be placed on the EU market or exported if they are deforestation-free, have been produced in accordance with the law of the country of origin, and have a due diligence declaration.

In this guide, we will explain, clearly and step by step, what will be required of you and what you must do to comply with the regulations. Furthermore, if you sell on marketplaces such as Amazon, this is also of interest to you. At LegaleGo, as an Amazon SPN partner, we can help you adapt your processes and manage all the necessary documentation.

1) What is the EIDR and who does it apply to?

The EUDR (EU Regulation on Deforestation-Free Products) seeks to break the link between consumption and deforestation. It affects anyone who places covered raw materials or their derived products, such as food supplements, on the EU market or exports them. This includes operators (those who introduce them for the first time) and traders (those who make them available afterwards).

This affects you if your company uses the following raw materials or manufactures certain products from them: cattle, cocoa, coffee, oil palm, rubber, soybeans, and timber.

2) Key implementation dates

Although the effective date is 2026, we recommend starting to gather the necessary information to be able to declare products deforestation-free, avoiding last-minute problems. Make a note of these dates:

Large and medium-sized enterprises: application from 30 December 2025.
Micro and small enterprises: applicable from 30 June 2026.

3) What they will ask you for (customers, marketplaces, and customs)

This will enable you to prove that your products are truly deforestation-free in accordance with regulations.

Due diligence declaration (DDD) submitted to the official EU system before placing the product on the market or exporting it. This DDD generates a reference number.
DDD reference number to link it to the customs operation and, where applicable, to B2B orders and marketplaces. Your customers may ask you for it.
Geolocation of the plots where the raw material was produced:
- Plots larger than 4 ha (except for cattle): industrial estates.
- Plots of up to 4 hectares: point or polygon.
- Cattle: point of each establishment through which the animal passed.
Production dates and legality checks in the country of origin (land use rights, permits, etc.). You must keep the documentation for 5 years.
Risk assessment (by country, area, mixture, traceability, etc.) and, where appropriate, mitigation measures to ensure zero or negligible risk.

4) How to prepare yourself. Do you meet all these requirements?

To ensure that your next import or sale can be declared as deforestation-free products, here is a series of requirements that your company must meet. Do you meet them all?

A. Define the scope

Make an inventory of affected products and ingredients (tariff codes/CN).
Confirm your role (operator or trader) as this determines your obligations.

B. Request critical data from suppliers now

Geolocation of plots (polygons or points, as applicable).
Production/harvest dates or ranges.
Proof of legality (titles, permits, licences).
Avoid mixtures of unknown origin: if you cannot separate them, the batch may be considered non-compliant.

C. Set up your Due Diligence System (DDS)

Register with the EUDR Information System and define who creates and signs each DDD.
Standardise your risk assessment.
Keep all documentation for 5 years.

D. Connect with your daily operations

Integrate the DDD number into your ERP and share it with logistics, customs, and B2B customers.
Include EUDR clauses in purchase contracts: data obligation, audits, and segregation.
Train in purchasing, quality and supply chain in the new flows.

5) If you sell on marketplaces (Amazon, etc.)

The EUDR applies to ‘placing on the market’, even if you sell on marketplaces. Many buyers and platforms are requesting the DDD number and evidence of traceability. At LegaleGo Regulatory Affairs, we are an Amazon SPN Partner, so we can help you prepare the documentation and inform you about the different processes so that your products, whether they are food supplements or not, are offered as deforestation-free products in the eyes of the platform and your customers.

6) What happens if you do not comply?

Beyond penalties, the commercial and reputational risk can be considerable. That is why it is essential to anticipate and be able to certify products as deforestation-free. Some of the penalties you may incur are:

Relevant fines (based on turnover in the EU).
Confiscation of goods and income and bans on selling.
Temporary restrictions on access to public procurement or financing.

7) Product-specific exemptions

The EUDR provides for specific exemptions by product type (or cases outside its scope) that should be reflected in this article.

Waste and products recovered or manufactured entirely from recycled material (e.g., wood from demolition or items made from by-products) are excluded, but this exemption does not extend to by-products from processes that use material that is not waste.

Used or second-hand products and product samples of negligible value and quantity intended for testing, analysis or approval are also excluded, as are packaging used exclusively to hold, protect or transport another product (pallets, boxes, wrappings) and ancillary materials such as manuals or catalogues, provided they do not contain relevant raw materials.

Furthermore, the Commission’s guidelines clarify that only products actually manufactured with a “relevant raw material” listed in Annex I are subject to the rules (the prefix “ex” is added to several codes to avoid including items without such raw materials).

Finally, in the timber and rubber sector, it has been confirmed that bamboo and rattan are excluded and that not all natural rubbers other than Hevea brasiliensis are covered. These exclusions and clarifications — included in the Commission’s guide and documents and disseminated by sectoral advisers — are also being communicated by marketplaces.

In the specific case of Amazon, its internal regulations state that products may be exempt from providing a reference and verification number if they meet any of the following conditions:

100% recycled raw material: all relevant raw materials in the product are fully recycled.
Harvest date: all relevant raw materials were harvested before 29/06/2023.
Marketing of raw materials in the EU: all relevant raw materials were marketed in the EU before 30/12/2025.
Marketing of the product in the EU: the product was marketed in the EU before 30/12/2025.
Product manufacturing date: the product was manufactured before 29/06/2023.

If batches of products were marketed in the EU before the date of entry into force of the Regulation, they may be exempt under the above points, although Amazon itself is likely to contact sellers to confirm the dates of manufacture.

At LegaleGo Legal Services, our colleagues have prepared a detailed analysis of the legal framework governing EUDRs. You can read the article by clicking here. It details the various European Union regulations and rules governing EUDRs.

As you know, at LegaleGo Regulatory Affairs we can ensure your EUDR compliance on deforestation-free products from start to finish: scope, geodata collection information, risk assessment, DDD, training and support for marketplaces, especially Amazon.

Do you have questions about how to certify that your products are deforestation-free? Write to us and we will guide you with a clear roadmap and all the legal guarantees.