EUDR from 30 December 2026: What goods and documents are required for deliveries to the EU?

From 30 December 2026, the main requirements of the EUDR—Regulation (EU) 2023/1115 on products associated with deforestation and forest degradation—will begin to apply in the European Union. For importers, this means mandatory verification of product origin. Suppliers from Ukraine and other non-EU countries will need to provide data without which their goods may be denied access to the EU market.

The EUDR is not simply another certificate required for customs clearance. The Regulation requires products to be traceable all the way back to the plot of land where the relevant commodity was grown, harvested or produced.

If a supplier fails to provide geolocation coordinates, consignment details and evidence of lawful production, the European importer will be unable to properly submit a due diligence statement (DDS).

When the EUDR Requirements Take Effect

The main EUDR application date is 30 December 2026. From that date, the requirements will apply to:

• large and medium-sized operators;
• large and medium-sized traders dealing in products covered by the EUDR;
• micro and small operators that were already subject to the European Union Timber Regulation (EUTR).

Most other micro and small undertakings established no later than 31 December 2024 will benefit from a transitional period until 30 June 2027.

However, the size of the Ukrainian supplier alone should not determine the approach taken. What matters is the status of the company that first places the product on the EU market or exports it from the European Union.

What Exactly Does the EUDR Prohibit?

A product covered by the EUDR may be imported, placed on the EU market or exported from the EU only if all three of the following conditions are met:

1. The product is deforestation-free and is not associated with deforestation after 31 December 2020.
2. The relevant commodity was produced in accordance with the laws of the country of production.
3. The product is covered by a due diligence statement (DDS) or by a simplified declaration where provided for under the Regulation.

For wood, forest degradation after the established cut-off date must also be taken into account.

Which Products Are Covered by the EUDR?

The Regulation covers seven main commodity groups:

• cattle;
• cocoa;
• coffee;
• oil palm;
• natural rubber;
• soy;
• wood.

However, the mere presence of one of these commodities in a product does not automatically bring that product within the scope of the EUDR. The decisive factor is its CN code under the EU Combined Nomenclature, as listed in Annex I to the Regulation.

This is an indicative list. Before entering into a contract, the specific Ukrainian Commodity Classification for Foreign Economic Activity 

code and its corresponding CN code must be checked.

For example, chocolate classified under heading 1806 falls within the scope of the EUDR because this code is expressly listed in Annex I. Equipment used to manufacture chocolate, however, is not covered by the EUDR merely because of its intended use.

The same principle applies to products containing rubber or wooden components: the classification code of the finished product must be checked first, rather than considering only the material composition.

Why the Product List Must Be Checked Again Before Dispatch

In July 2026, the European Commission adopted a delegated act amending Annex I. It provides for the exclusion of cattle hides and leather, retreaded tyres, soybean seed for sowing, certain rubber products, and motor vehicle and aircraft seats from the scope of the EUDR.

At the same time, it proposes adding instant coffee, certain palm oil derivatives and frozen bovine tongues to the list. The requirements for these newly added product categories are expected to apply from 30 December 2027.

As of the date this article was prepared, the act had been submitted to the European Parliament and the Council of the EU for scrutiny and had yet to complete the procedure required for it to enter into force. The final status of a product must therefore be determined using the version of Annex I in force on the date of filing, rather than an outdated list or the product's commercial description.

Does the EUDR Apply to Wooden Pallets and Packaging?

It is important to distinguish between goods and transport packaging.

If wooden crates, skids or pallets are sold as standalone products, their CN code may bring them within the scope of the EUDR. Packaging material used exclusively to support, protect or carry another product, however, is generally not treated as a separate product subject to the EUDR.

For example:

• a consignment of new wooden pallets sold as goods may be subject to the EUDR requirements;
• pallets carrying boxes of industrial equipment are generally treated as transport packaging;
• wooden components included in a shipment as standalone items must be classified separately.

The final determination is based on the product's function, the terms of supply and its CN code.

Who Is Responsible for EUDR Compliance When Goods Are Supplied from Ukraine?

When a Ukrainian company supplies products to a European buyer, the obligation to submit the DDS usually falls on the first EU-established operator that places the goods on the European market. In most cases, this is the importer.

The non-EU supplier must nevertheless provide the importer with all the underlying information, including:

• the origin of the relevant commodity;
• the coordinates of the production plots;
• the period of production or harvesting;
• documents demonstrating the lawful use of the land and commodity;
• data tracing the consignment through the supply chain.

Without this information, the importer will be unable to carry out the required checks and assume responsibility for the product's compliance with the EUDR.

Incoterms rules do not, by themselves, determine responsibility under the EUDR. In the case of DDP deliveries, direct sales through an EU-based subsidiary or transactions involving a related importer, the parties must separately determine which company qualifies as the operator under the Regulation.

What Documents and Data Will Be Required?

The Regulation does not establish a single checklist of documents with fixed names. The evidence required depends on the product, the country of production and the structure of the supply chain. However, the basic set of information and documents is as follows.

The main objective is to maintain an uninterrupted link between the production plot, the specific commodity and the consignment being shipped. Separate documents that do not share a common consignment identifier do not provide full traceability.

What Does Geolocation Mean Under the EUDR?

Stating only the country or region of origin is not sufficient. The operator requires the coordinates of every plot of land on which the relevant commodity used in the product was produced.

If a consignment contains products sourced from several farms or production sites, the information must include all the relevant plots. Mixing consignments without preserving the link to their respective origins creates a risk that the entire shipment will be deemed non-compliant.

For products of animal origin, the locations where the cattle were kept must be provided. For plant-based commodities and wood, the relevant cultivation or harvesting plots must be identified.

Coordinates can be uploaded to the EU information system, including in GeoJSON format. The same system is used to enter the product code, description, weight, volume and other consignment details.

Is a Separate EUDR Certificate Required?

There is no universal EUDR certificate that a supplier can obtain once and reuse for every shipment.

The principal electronic document is the due diligence statement. The operator submits it through the EU information system after:

1. Collecting the required information and supporting evidence.
2. Assessing the risk that the product does not comply with the EUDR.
3. Taking risk-mitigation measures if the risk is more than negligible.

Once the statement has been registered, the system assigns it a reference number. For goods imported into or exported from the EU, this number must be available to customs before the goods are released.

FSC, PEFC, Rainforest Alliance and other industry certifications may be used as part of the supporting evidence. However, they do not replace EUDR due diligence and do not relieve the operator of responsibility.

Likewise, a certificate of origin or an EUR.1 movement certificate cannot replace the DDS. These documents serve different purposes, including confirming the origin of goods for the application of preferential tariff treatment.

How Is the EUDR Linked to Customs Clearance?

The DDS is not a standard attachment to a commercial invoice. The statement is submitted through a separate information system, and its reference number is provided to customs.

For a product subject to the EUDR, the process is as follows:

1. The supplier compiles the information relating to the origin of the consignment.
2. The European operator verifies the information and assesses the risk.
3. The operator submits the DDS through the EUDR Information System.
4. The reference number is linked to the customs declaration.
5. Customs and the competent authorities decide whether the goods may be released.

If a product's CN code is included in Annex I and the DDS reference number is missing, invalid or does not correspond to the consignment, the release of the goods for free circulation may be suspended.

Preparation for EUDR compliance should therefore begin before the truck or container is loaded—not after the goods arrive at the border. Customs clearance in EU countries must be coordinated with the importer in advance.

Which Errors Can Delay a Shipment?

In practice, the greatest risk is not the absence of a single document, but inconsistencies between different sources of information:

• the CN code has been determined only approximately;
• the documents state only the country of origin without providing geolocation data;
• the coordinates do not cover every plot represented in a mixed consignment;
• the weight stated in the DDS differs from the net weight shown in the invoice and customs declaration;
• the manufacturer's documents cannot be linked to the consignment being shipped;
• a standard certificate of origin is used instead of conducting EUDR due diligence;
• the DDS reference number is obtained only after the vehicle has arrived;
• responsibility is incorrectly shifted to the carrier;
• the presence of wood or rubber in a product is treated as sufficient grounds for applying the EUDR without checking the classification code of the finished product.

A commercial invoice, packing list, CMR consignment note or bill of lading does not, by itself, prove that a product is deforestation-free. However, the information in these documents must match the data used during the due diligence process and when submitting the DDS.

How to Prepare Your First Shipment for EUDR Compliance

It is best to begin preparing with a specific product and route:

1. Determine the exact CN code.
2. Confirm that it is listed in the current version of Annex I.
3. Identify the European operator responsible for submitting the DDS.
4. Trace the supply chain back to the producer of the relevant commodity.
5. Collect the coordinates of all production plots and the production dates.
6. Link this data to the export consignment number.
7. Check that the invoice, packing list and transport documents are consistent.
8. Agree who will submit the DDS and when.
9. Provide the reference number for customs clearance.
10. Define each party's responsibility for the accuracy of the data in the contract.

If the supplier cannot establish the origin of part of a mixed consignment, the safest option is to exclude that part from any shipment intended for the EU market until the verification has been completed.

How Save Pro Solutions Helps Prepare Your Shipment

When transporting regulated goods, the exporter, European importer, customs broker, carrier and consignee must coordinate their actions. An error at any point in this chain may delay the vehicle and result in additional costs.

Save Pro Solutions can help you:

• review the proposed logistics arrangements;
• cross-check the commercial and transport documents;
• arrange international freight transportation to Europe;
• coordinate with the importer and customs representative;
• identify discrepancies in the weight, codes and consignment description in advance;
• prepare documents for customs clearance in the EU.

The obligation to submit the DDS and the legal responsibility for product compliance remain with the operator designated under the Regulation. Before dispatch, the parties must therefore define not only the route but also the roles of everyone involved in the transaction.

Conclusion

The EUDR changes the entire approach to supplying wood, coffee, cocoa, soy, natural rubber, oil palm commodities and cattle products to the European Union.

Stating the country of origin and providing a standard certificate is not enough for a product to be admitted to the market. The European operator will require the exact CN code, consignment details, the coordinates of all production plots, evidence of lawful production, and a traceable link between the relevant commodity and the finished product.

The main requirements will begin to apply on 30 December 2026, but the supply-chain data must be prepared well in advance. If the origin of the goods is investigated only after the truck or container has arrived, the shipment may be delayed until the verification process has been completed.