EUDR: Deforestation Regulation for Online Retailers 2026

The EU Deforestation Regulation (EUDR) forces retail to rethink its data: anyone selling or exporting products containing coffee, cocoa, wood, leather, rubber, soy, cattle, or palm oil in the EU must prove these were produced deforestation-free. Seven commodities account for around 40% of global tropical deforestation (WRI), and the EU is considered responsible for around 16% of trade-driven deforestation worldwide (WWF). For online retailers, this means capturing geolocation data, filing a due diligence statement (DDS) in the EU information system TRACES, and passing reference numbers along the supply chain. After the second postponement in December 2025, the obligations apply from 30 December 2026 for large and medium operators and from 30 June 2027 for small and micro operators (Regulation EU 2025/2650). This guide explains what shop operators face in 2026 and how to integrate the data requirements cleanly into shop, PIM, and ERP.

What the EU Deforestation Regulation Requires of Retailers

The EUDR (Regulation EU 2023/1115) entered into force on 29 June 2023 and replaces the former EU Timber Regulation. Its goal: products from deforestation and forest degradation should disappear from the EU market. Unlike a voluntary label, the EUDR is a binding market access requirement for all seven covered commodities and the products derived from them. The decisive cut-off date is 31 December 2020: only goods from land not cleared for production after that date may be placed on the market (European Commission).

The regulation distinguishes between operators, who first place a product on the EU market or export it, and traders, who trade it further. Who bears which obligation in the supply chain depends on this role and on company size. For many online stores and Shopware projects, classification as an operator is relevant, for example when they import coffee, furniture, or leather goods directly from non-EU countries and sell to end customers.

The EUDR is thus part of a growing bundle of EU sustainability rules that also includes the Green Claims Directive on advertising claims and the EU Packaging Regulation PPWR. Building your data processes now creates a foundation that supports several of these frameworks at once.

The Seven Affected Commodities and Their Products

The EUDR covers seven commodities: cattle, cocoa, coffee, oil palm, rubber, soy, and wood (European Commission). What matters for retail, however, is that not only the raw commodities but also a long list of derived products is affected. These include beef and leather, chocolate, furniture, paper and books, tires, soybean oil, and many other goods. Which specific item falls under the rules? The decisive factor is the respective HS code (customs tariff number) in Annex I of the regulation.

Shop operators should therefore start with a product range analysis: which items contain affected commodities, and via which HS codes are they imported? Only this inventory reveals which part of the catalog falls under the due diligence obligation. A well-maintained PIM system is the natural place to store commodity origin, HS codes, and EUDR status per product. In practice, retailers underestimate how many seemingly uncritical items are affected: an office chair with leather upholstery and wooden parts, a cosmetic with palm oil derivatives, or a book all touch several commodity chains. The inventory creates clarity here and forms the basis for every further step.

Due Diligence in Three Steps: Geolocation, DDS, TRACES

Due diligence follows a clear chain of three steps. In the first step, the operator collects information: description and quantity of the goods, the producer country, and the geolocation of all production areas. In the second step, they assess the risk that the goods are not deforestation-free or not legal - taking into account the risk classification of the country of origin. In the third step, they mitigate any risks, for example through additional evidence, and only then file the due diligence statement.

1. Collect information - compile product description, HS code, quantity, producer country, supplier, and geolocation data of all production plots
2. Assess risk - evaluate deforestation and legality risk based on the country risk classification, supplier information, and the plausibility of the geodata
3. Mitigate risk - where risk is more than negligible, obtain additional evidence, audits, or satellite checks until the risk is negligible
4. File the DDS - submit the due diligence statement with all data in the EU information system TRACES and document the reference number
5. Pass on the reference - forward the DDS reference number to downstream operators so they can fulfill their own obligation

This chain is data-intensive and generally repeats per batch. Anyone mapping it manually in spreadsheets quickly hits limits as the product range grows. A systematic connection of shop, PIM, and ERP ensures the data is captured once and then used automatically for the DDS and supply chain communication.

Geolocation Data: The Heart of Compliance

The technical core of the EUDR is geolocation. For each production plot, precise geographic coordinates (latitude and longitude) must be provided. For plots larger than 4 hectares, a single point is no longer sufficient - here a polygon outlining the area is required (European Commission). For cattle, all holdings are recorded instead. Coordinates can be uploaded individually, in bulk, or in the standardized GeoJSON format.

This is precisely where it is decided whether EUDR compliance becomes a permanent burden or a manageable process. The geodata must not only be captured but maintained, versioned, and linked to the respective product on an ongoing basis. In B2B e-commerce with complex supply chains, it makes sense to keep geolocation and proof of origin as structured attributes in the PIM and to transfer them automatically into DDS workflows via interfaces, rather than collecting them in loose documents.

The Due Diligence Statement in the EU Information System TRACES

The due diligence statement (DDS) is the formal declaration by which an operator confirms they have fulfilled their due diligence obligation. It is submitted via the EU information system, which runs on the European Commission's TRACES NT platform (European Commission). A DDS typically contains the geolocation data of the production areas, commodity and HS codes, supplier information, the results of the risk assessment, and the steps taken to mitigate risk.

After successful submission, the system generates a DDS reference number and a verification code. This reference is the key to the entire supply chain: downstream operators and traders can refer to existing statements instead of collecting every piece of information again. With the simplifications from December 2025 (Regulation EU 2025/2650), only actors who place products on the EU market or export them need to file their own DDS; downstream non-SMEs merely register and retain the reference numbers. While this division of tasks relieves individual links in the chain, it shifts the responsibility for complete and correct data to the front. Whoever acts as the first to place goods on the market bears the full due diligence burden and should make their data processes robust accordingly.

Besides the web interface, TRACES also offers a programmatic connection. For retailers with many affected items, an interface integration can make the difference, because DDS datasets are prepared from shop and ERP data and reference numbers are written back automatically. This keeps the process manageable even as order volume rises - a topic closely tied to scalable shop infrastructure.

Deadlines, Company Sizes, and Simplified Obligations

The application deadlines have been postponed several times. After the second postponement in December 2025: for large and medium-sized companies, the EUDR applies from 30 December 2026, for small and micro enterprises from 30 June 2027 (Regulation EU 2025/2650). These staggered dates give smaller retailers more time but do not change the operational effort: anyone who has not yet digitized their supply chains is, according to industry observers, already behind (IntegrityNext).

At the same time, the estimated compliance costs fall considerably with the simplifications. The European Commission expects annual compliance costs to drop from around EUR 8.1 billion (as of 2023) to about EUR 2.0 billion - a reduction of around 75% (European Commission). Nevertheless, smaller firms bear relatively higher burdens: on average they spend 0.17% of revenue on compliance, while large firms spend only 0.06% (European Commission).

The country risk classification plays a central role here. In May 2025, the Commission published the first benchmark: 140 countries were classified as low-risk (including all EU member states, the US, Canada, China, and Ukraine), four countries as high-risk (Belarus, Myanmar, North Korea, and Russia), and all others as standard risk (White & Case). For goods from low-risk countries, simplified due diligence applies, which further underlines the importance of clean origin data.

Risks of Non-Compliance: Fines and Market Bans

The EUDR is backed by tangible sanctions. For legal persons, the maximum fine is at least 4% of total EU annual turnover of the operator in the preceding financial year (Regulation EU 2023/1115). Where economic benefits are particularly high, the maximum can be raised even further so that the penalty exceeds the benefit gained.

• Fines - at least 4% of EU annual turnover, raised if necessary beyond the economic benefit gained
• Confiscation of goods - seizure of the affected commodities and derived products
• Confiscation of revenues - skimming of the income from the relevant transaction
• Exclusion from procurement - temporary exclusion from public tenders and funding for up to twelve months
• Distribution ban - temporary prohibition on placing affected goods on the market or exporting them in case of serious or repeated infringements

For retail, besides the financial risk, the critical factor is ability to supply: without a valid DDS, an affected product may not be placed on the market. Missing or faulty geodata can therefore mean entire product groups become unsellable. This makes the EUDR a topic that does not concern the legal department alone but directly affects the product range, strategic consulting, and revenue. A robust data process is thus also a contribution to trust signals and supply reliability toward customers. Experience shows it pays to identify affected product groups early and to make binding agreements with suppliers on the provision of geodata and proof of origin before the deadline applies - sourcing data at the last minute before the cut-off is typically far more demanding and error-prone.

Shop and Data Integration as the Compliance Foundation

The EUDR is first and foremost a data challenge. Geolocation, HS codes, supplier evidence, risk assessments, and DDS reference numbers must be captured, checked, linked, and retained in an audit-proof way - on an ongoing basis, not just once. Anyone managing this information in spreadsheets and email attachments risks gaps as soon as the range grows or suppliers change. An integrated solution, by contrast, captures the data at the source and makes it available automatically for the DDS and supply chain communication.

In practice this means: the PIM system holds EUDR attributes such as commodity origin, geocoordinates, and EUDR status per product. The ERP supplies quantities, batches, and supplier data. The online store links orders to the matching DDS references. Via interfaces, these datasets are prepared for submission in TRACES and the reference numbers are written back. The result is an end-to-end process that grows with the catalog instead of collapsing with it.

Anyone maintaining EUDR data in a structured way anyway also creates the basis for neighboring frameworks such as the Digital Product Passport (DPP) and the EU Data Act, which likewise rely on machine-readable product and supply chain data. The investment in a clean data infrastructure therefore pays off multiple times. As an e-commerce agency with interface experience, we help you anchor geolocation, DDS workflows, and supply chain data in shop, PIM, and ERP so that the obligation becomes a manageable, scalable process.

Frequently Asked Questions on the EU Deforestation Regulation