Regulation 2023/1115: after two postponements, large and medium operators apply from 30 December 2026. Geolocation and due diligence have to exist before the statement does.
A due-diligence statement can be filed in a portal. It cannot invent the plot, the cut-off date or the supplier file behind it.
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.
The plot is the operating test
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.
The risk is not only a missing filing. It is reaching 30 December with products in the catalogue that cannot be mapped to land, legality or a named supplier.
Where readiness 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 that remain 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.
These are connected decisions. Treating sourcing, master data and the due-diligence statement as separate projects leaves the organisation to assemble a file under a placing-on-the-market clock.
What Ontzi builds
Ontzi turns the obligation into a due-diligence operating model. We connect a supplier portal and product database to geolocation and evidence collection, put risk assessment in the path to a statement, and keep the trail that downstream operators and authorities can follow.
The immediate output is the ability to place or export. The durable value is a repeatable capability: the organisation knows which products are in scope, which land they came from, who owns the risk decision and what was filed.
The statement is the last step. The operating model is what makes it defensible.
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.