Regulation 2023/1115: after two postponements, large and medium operators apply from 30 December 2026. The statement needs geolocation of the plots of land.
Regulation (EU) 2023/1115 — the EU Deforestation Regulation — allows cattle, cocoa, coffee, oil palm, rubber, soya and wood, and listed derived products, onto the Union market or out of it only if they are deforestation-free, legal in the country of production, and covered by a due-diligence statement. “Deforestation-free” means the land was not deforested or degraded after 31 December 2020.
The application date has moved twice. Under Regulation (EU) 2025/2650, large and medium operators apply from 30 December 2026. Micro and small operators follow on 30 June 2027, except those already covered by the EU Timber Regulation, who stay with the December date. Downstream operators and traders no longer each file a full statement; the operator who first places the product on the market carries the due-diligence duty, and others keep and pass on the reference.
Plot, not country of origin
Due diligence is three connected steps: collect information, assess risk, mitigate it until it is negligible. The information includes geolocation of the plots of land, production time, supplier identity and evidence that the goods are legal and deforestation-free. Country benchmarking (low, standard, high risk) changes how heavy the assessment is — it does not remove the need to know the plot.
The evidence sits with farms, mills, traders and the product bill of materials. A sustainability policy, a country-of-origin field or a certificate that cannot be tied to a consignment will not support a statement. The Information System exists; it does not gather geolocation or decide risk for the operator.
Where it breaks
- Products: which SKUs contain a relevant commodity, in which form, and who first places them on the Union market.
- Evidence: plot geolocation, production period, legality and deforestation-free proof attached to the consignment, not to a generic supplier folder.
- Workflow: who assesses risk, who mitigates it, who files or passes on the reference, and how a substantiated concern is handled.
What we build
Supplier and product data sit with geolocation and evidence. Risk assessment sits in the path to a statement. Downstream operators and authorities get a trail they can follow.
Primary text
- Regulation (EU) 2023/1115 — official text
- EUR-Lex summary of the deforestation-free product rules
- Commission page on deforestation-free products
This field note is general information, not legal advice. Scope, operator category, country risk and the latest amendments should be checked for each operator.