EUDR June 2026: coffee, cocoa, wood imports really change

EU regulation 2023/1115 (EU Deforestation Regulation, EUDR) is one of the most structuring texts of the decade for distributors. After the one-year postponement obtained in December 2024, it enters into application on 30 December 2025 for large companies and 30 June 2026 for SMEs. Seven products are covered: coffee, cocoa, wood, soy, palm oil, rubber, cattle, and their derivatives (chocolate, leather, furniture, paper).

What EUDR requires, in practice

For each batch imported or placed on the European market, the operator must produce a Due Diligence Statement (DDS). This statement certifies that the product does not come from a zone deforested after 31 December 2020, that it was produced in compliance with the law of the origin country, and that it is traceable to the agricultural or forestry plot (with GPS coordinates).

The DDS is filed on the TRACES NT (Trade Control and Expert System) portal managed by the European Commission. It receives a reference number (DDS-ID) that must follow the batch throughout the chain. Without a DDS-ID, the batch cannot be declared at customs entering the European market.

The geolocation challenge

The regulation requires geolocation of origin plots. For coffee and cocoa, which come 80% from smallholder producers (Côte d'Ivoire, Ghana, Vietnam, Brazil), this implies mapping each plot — technically possible (drones, satellite, ground GPS) but requiring investment and cooperation many importers don't have.

For cooperatives, declaring an enclosing polygon is allowed. But the polygon must not exceed 4 hectares in some cases, and must be cross-checkable with satellite forest-cover data (Hansen Global Forest Change, GLAD alerts). A plot that turns out, on analysis, to be located in a zone deforested after 2020 leads to batch rejection — and operator liability.

Application grey zones

Specialty coffee shops

Is a specialty store reselling coffee imported by a French roaster subject to EUDR? The Commission's answer is clear: yes, as a "trader", it must ensure the upstream chain has indeed produced the DDS. In practice, this means collecting and archiving DDS-IDs of all suppliers and being able to present them on request of the control authority (in France: DGCCRF).

Furniture and paper

A wooden-furniture or printing-paper reseller is concerned. The complexity: for a piece of furniture composed of several wood species, the DDS must cover each component. For paper made of mixed recycled and virgin fibres, only virgin fibres are concerned. Suppliers (often Asian) are not all at the level, creating an import bottleneck.

Bovine leather

Leather being a bovine derivative (covered by EUDR), every imported leather product must be traceable to the origin farm. For luxury leather goods, this is manageable (chains are already heavily tracked). For fast fashion or entry-level footwear, it is a major operational challenge — entire brands may have to reformulate their sourcing.

What forward-looking distributors are doing

Players that anticipated (essentially food retail and premium chocolate operators) have structured three work-streams. First, mapping critical suppliers: who brings EUDR products, from where, under which DDS, with how much confidence in the data. Second, TRACES NT integration: direct API connection to retrieve DDS-IDs in real time, rather than as email attachments. Third, the archive chain: 5 years of DDS retention and supporting evidence, with timestamping and audit accessibility.

For SME distributors or traders who haven't started, June 2026 will be brutal. There are 60 days left.