Deforestation-free production
Assess the 31 December 2020 cut-off date and the definitions relevant to the commodity and product.
EUROPECARBON · EU sustainability legislation
EUDR Consultancy
Prepare product classification, supply-chain traceability, plot-level geolocation and due diligence evidence for your EU customers. EUROPECARBON brings these requirements together in a practical, role-specific work plan.
What is EUDR?
The EU Deforestation Regulation, Regulation (EU) 2023/1115, establishes requirements for specified commodities and products listed in Annex I that are placed on, made available on or exported from the EU market. The framework concerns deforestation-free production, compliance with relevant legislation in the country of production and applicable due diligence obligations.
Scope is not determined by sector name alone. The current Annex I, product description, CN code and economic operator role must be considered together. EUDR is not a certification scheme.
Three core compliance conditions
Legal production
Review evidence against the relevant legislation in the country of production.
Role-specific due diligence
Identify information collection, risk assessment, risk mitigation and statement responsibilities applicable to the operator.
Which products fall within EUDR?
The seven commodity groups are cattle, cocoa, coffee, oil palm, rubber, soya and wood. Only the products covered by the applicable Annex I fall within scope.
Use this table for preparation only, not binding customs classification. For tyres, leather, processed coffee and other derived products, check the current official Annex I instead of assuming that an entire sector is included or exempt.
| Commodity group | Examples to assess | Initial checks |
|---|---|---|
| Wood | Timber, wood-based products and specified furniture or paper products | Current Annex I code, harvest information and forest plot |
| Rubber | Natural rubber and specified derived products | Exact CN code, product description and current Annex I |
| Coffee and cocoa | Beans and specified processed products | Product code, production country and farm/plot linkage |
| Cattle, oil palm and soya | Listed commodities and derived products | Origin, traceability and applicable product-code exceptions |
Legal reference: Regulation (EU) 2023/1115 and applicable amendments. Refer to the current official text and applicable exceptions.
EUDR application dates and transitional provisions
Regulation (EU) 2025/2650 amended the application schedule. Check Article 38 and the transitional provisions relevant to your business size, legal role and product before setting a compliance deadline.
30 December 2026
Main application date for large and medium-sized operators and specified smaller timber-related businesses.
30 June 2027
Most eligible micro and small operators, subject to the conditions and exceptions in the amended Article 38.
30 December 2027
Specified newly added products under Delegated Regulation (EU) 2026/2102. This is not a general extension for all products.
Legal reference: Regulation (EU) 2023/1115 and applicable amendments. Refer to the current official text and applicable exceptions.
Six practical EUDR work packages
01 · Product and CN-code screening
Map products against Annex I, distinguish out-of-scope items and build a product portfolio matrix.
02 · Role and responsibility assessment
Separate the responsibilities of the EU operator, downstream participants, traders and supplier in Türkiye.
03 · Supply-chain traceability
Connect raw material, producer, batch, shipment and supplier records into an evidence chain.
04 · Geolocation data preparation
Review plots, coordinates, polygon requirements, data completeness and missing fields.
05 · Risk and evidence review
Assess deforestation risk, legal production and data reliability, with risk mitigation where required.
06 · DDS and customer evidence support
Prepare the records, statement-support information and technical data package required by the applicable legal role.
From production plot to EU customer: an evidence chain
The central issue is not a single certificate, but a verifiable link between the product and its production source. Production location, coordinates, commodity descriptions, production period, batch relationships and legal-production evidence should be connected.
A typical sequence is production plot and coordinates → raw material and origin evidence → supplier and batch → shipment and CN code → evidence package for the EU customer. Missing or inconsistent records are tracked separately.
Outputs include a product-code matrix, supplier data-request list, evidence-gap report and role-based responsibility map. Data formatting alone is not geospatial verification or a legal compliance decision.
EUDR preparation for exporters in Türkiye
Rubber and tyre supply chains
Natural rubber origin, exact product codes and EU customer evidence requests.
Wood, furniture and paper
Harvest areas, wood inputs, batch-level traceability and product-code distinctions.
Coffee and cocoa
Farm and plot data, production origin and Annex I mapping for processed products.
Manufacturers supplying the EU
An evidence package distinguishing the supplier’s data responsibilities from the EU operator’s statutory obligations.
Due diligence: data, evidence and controls
This matrix supports an initial assessment. The applicable process must reflect the current legal role, simplifications and exemptions.
| Control | Data and evidence | Legal reference |
|---|---|---|
| Product and quantity | Description, CN code, trade name, quantity and commodity | Article 9 |
| Supply chain | Producer and supplier, production country and period, batch and shipment links | Article 9 |
| Geolocation | Production plots, coordinates, applicable polygons and cattle establishments | Articles 2 and 9 |
| Deforestation-free evidence | Land use, production, satellite or mapping evidence against the cut-off date | Articles 3, 9 and 10 |
| Legal production | Relevant land-use, environmental, forest, labour and human-rights evidence | Articles 3, 9 and 10 |
| Risk and mitigation | Source reliability, inconsistencies, country risk and additional verification | Articles 10 and 11 |
| Statements and records | Applicable declaration or statement process and record retention | Article 4 and applicable amendments |
Legal reference: Regulation (EU) 2023/1115 and applicable amendments. Refer to the current official text and applicable exceptions.
Geolocation: points, polygons and the four-hectare threshold
Subject to the specific rules for cattle establishments, production plots of four hectares or less may be represented by a coordinate point; plots above four hectares require a polygon describing the perimeter.
Coordinates must meet the regulatory precision requirements. Relevant plots contributing to a shipment must be assessed. A valid GeoJSON file is not, on its own, proof of legal production or deforestation-free status.
- Identify every relevant production plot.
- Check coordinate precision and applicable polygon requirements.
- Link plot data to production period, commodity and batch.
- Resolve missing data and inconsistent supplier records.
Legal reference: Regulation (EU) 2023/1115 and applicable amendments. Refer to the current official text and applicable exceptions.
Country risk and enforcement
The EU benchmarking framework classifies countries as low, standard or high risk. Low risk is not a general product exemption: information requirements and the conditions for simplified due diligence still need to be assessed.
Country risk concerns where the relevant commodity was produced, not simply the country exporting the finished product. Imported wood used in furniture made in Türkiye requires assessment of the wood’s production origin.
Article 25 requires effective, proportionate and dissuasive penalties. For legal persons, the framework includes a maximum fine of at least 4% of annual Union-wide turnover. The actual penalty depends on the infringement and national implementation.
Legal reference: Regulation (EU) 2023/1115 and applicable amendments. Refer to the current official text and applicable exceptions.
Starter scope and data-readiness package
Duration and quotation depend on product count, supplier count and existing data quality. This service does not issue an official EUDR certificate.
01 · Scope report
Product list, preliminary CN mapping, applicable Annex I, exceptions and role matrix.
02 · Evidence-gap analysis
Checklist for supplier, plot, production period, batch and legal-production evidence.
03 · Roadmap
Prioritised actions, responsibilities, risk topics and a plan for the EU customer data package.
EUDR and PPWR: wooden pallets and packaging
Placing wooden packaging or a pallet on the market as a product in its own right is not the same as using packaging to support or protect another product. Assess EUDR scope against function and CN classification. PPWR addresses packaging requirements; neither regulation replaces the other.
Discuss your requirements with EUROPECARBON
Ersin ÇETİN
Sustainability Specialist · 15+ years of experience
Contact us to discuss your products, evidence gaps and EU customer requirements. This English content is general information, not a product-specific legal opinion or certification.
EUDR scope precheck
Provide the information needed for a product-code and legal-role assessment. This precheck does not determine legal scope or issue a DDS.
Frequently asked questions
Is there an official EUDR certificate?
There is no universal official EUDR certificate for all businesses. FSC or PEFC certification may support particular evidence but does not automatically replace statutory due diligence responsibilities.
When does EUDR apply?
Under Regulation (EU) 2025/2650, the main application date is 30 December 2026 for large and medium-sized operators and 30 June 2027 for most eligible micro and small operators. Exceptions and product-specific transitional provisions must be checked.
Must every exporter in Türkiye submit a DDS?
No. Responsibility depends on the legal role and transaction in the EU market. Suppliers may need to provide data to EU buyers without having the same statement obligation as the operator.
Are tyres, rubber and leather products covered?
Assess the exact product description and CN code against the current Annex I. Do not assume all products in a sector are included or exempt.
What geolocation data is needed?
Relevant production plot locations and other required production information must be reviewed by product and role. Coordinate precision, polygon requirements and supplier-data verifiability require separate checks.
Is EUDR the same as CBAM?
No. CBAM concerns embedded carbon emissions for specified goods; EUDR focuses on deforestation and supply-chain due diligence. Data-management workflows may share practical elements.
Request EUDR consultancy
Share your company’s activities and customer requirements so we can define the assessment scope.
Official sources and related services
- Regulation (EU) 2023/1115 — official EUDR text
- Regulation (EU) 2025/2650 — revised dates and responsibilities
- Delegated Regulation (EU) 2026/2102 — Annex I amendments
- European Commission — deforestation-free products
- European Commission — roles and responsibilities
- European Commission — GeoJSON documentation
- Commission Implementing Regulation (EU) 2025/1093 — country benchmarking
PPWR consultancy · CBAM reporting · EcoVadis consultancy · Life cycle assessment
English content updated: 11 October 2026. General information only. Applicable legal obligations must be confirmed for the specific product and economic operator.