EUDR traceability data: what the Deforestation Regulation needs

What does EUDR require?

EUDR prohibits placing seven commodities and their derived products on the EU market, or exporting them, unless they are deforestation-free, legally produced and covered by due diligence. For product data teams, the question is which SKUs are in scope and which references must travel with them. The product data compliance pillar explains how EUDR sits next to PPWR, ESPR and GPSR.

The commodities are cattle, cocoa, coffee, oil palm, rubber, soya and wood. Derived products are listed by HS code in Annex I, which brings in leather goods, chocolate, furniture, paper, packaging and tyres.

EUDR places three duties on operators:

1. Collect information, including the geolocation of every plot where the commodity was produced.
2. Assess and mitigate the risk of deforestation and illegality.
3. Submit a due diligence statement to the EU information system before placing the product on the market.

Most of this is supply-chain data. The product data team's part is the scope: knowing which products contain in-scope commodities, under which HS codes, and making that visible to customers.

Which data does EUDR require?

EUDR data splits into product-level data the PIM can hold and batch-level data that belongs in traceability systems. The table shows each attribute and where it usually lives.

In PIMvendors engagements, the PIM's contribution is the first four rows plus a link to statement references where customers need them. Retailers and distributors ask for the in-scope flag and HS code in supplier templates and data pool feeds.

EUDR dates after the second postponement

EUDR now applies from 30 December 2026 for large and medium operators and from 30 June 2027 for micro and small operators. The list below shows all milestones with sources.

1. 18 December 2025
   Council adopts second revision

   The Council signed off the targeted revision that postpones and simplifies EUDR.

   Fixed Source

2. 26 December 2025
   Regulation (EU) 2025/2650 in force

   Amending regulation published on 23 December 2025 entered into force three days later.

   Fixed Source

3. 30 April 2026
   Simplification review due

   Commission report on the simplification review, with a legislative proposal where appropriate; outcome to be confirmed.

   Fixed Source

4. 30 December 2026
   EUDR applies, large and medium

   Due diligence and prohibition apply to large and medium operators and traders.

   Fixed Source

5. 30 June 2027
   EUDR applies, micro and small

   Micro and small operators receive six additional months.

   Fixed Source

The original application date was 30 December 2024. A first amendment moved it by one year. Regulation (EU) 2025/2650, adopted on 17 and 18 December 2025 and in force since 26 December 2025, moved it again and simplified the duties.

The same revision required a simplification review by 30 April 2026. Commission statements before the review pointed to targeted implementation changes, such as revised guidance and an Annex I delegated act, with the core text kept. PIMvendors had not verified the review outcome at the time of writing, so check the Commission's EUDR pages before relying on scope details.

For product data teams, 30 December 2026 is close. The in-scope flag and HS codes should be in the PIM before the end of 2026, so customers and the traceability system can rely on them.

What changed for downstream operators and traders?

Downstream operators and traders now collect and keep information instead of repeating full due diligence. That shifts their product data focus to supplier and customer records and statement references.

Under the December 2025 revision:

• Downstream operators and traders keep specified supplier and customer information for five years.
• Non-SME downstream operators and traders register that information in the EU information system.
• Declaration reference numbers are needed only where the supplier is an operator.
• With a concrete indication of non-compliance, non-SME companies verify that due diligence was done and inform authorities; SMEs inform authorities.

For distributors and retailers, the practical work is in supplier onboarding: request the in-scope flag, HS code and statement reference with every relevant product. The supplier data onboarding page covers template design. Food and beverage companies with cocoa, coffee or palm oil derivatives can use the food and beverage industry page for the wider data model.

How do you test EUDR readiness in a PIM selection?

Test EUDR readiness with a scope scenario: can the PIM find every in-scope product and pass the references downstream. PIMvendors' scenario method uses the buyer's own assortment for this.

1. Import 200 products with HS codes and flag in-scope items by rule.
2. Show the list of in-scope SKUs per commodity in under a minute.
3. Link a due diligence statement reference to a product and a shipment record from ERP.
4. Export the in-scope flag and HS code to a retailer template or data pool.
5. Show the audit trail when an HS code changes.

Score each step on effort and audit trail.

EUDR also touches packaging data, because Annex I lists wood-based paper products and the 2026 Annex I draft discussed exemptions for packaging. Coordinate EUDR scope with your PPWR packaging data, so packaging materials are classified once.