EU deforestation rules: what online sellers should prepare now
Check affected products, supplier evidence and who handles due diligence before EUDR’s main 30 December 2026 start. Later dates depend on the operator and exact product; they are not a blanket extension for small online shops.
- Who this affects
- UK online sellers supplying EU customers with products listed in EUDR Annex I. Exact product scope, supply-chain role and operator eligibility determine what applies.
- Seller action
- Check before sending affected goods
Check the product and code, agree who imports and handles due diligence, request supplier evidence and test the reference handover. Confirm your own deadline before relying on a later date.
- Effective dates / current position
- Product-list amendment enters into force: — In forceMain EUDR obligations: — Upcoming—not yet in forceArticle 38(3) qualifying operators; EUTR products excluded: — Upcoming—not yet in forceSpecified deferred new product entries: — Upcoming—not yet in forceTiming follows the confirmed published schedule; it is not a fresh legal review. Partly in force includes the September product-list amendment; the main obligations apply from December 2026. The June 2027 extension is only for Article 38(3) qualifying operators established as such by 31 December 2024, excluding EUTR-Annex products; it is not a blanket small-retailer extension. December 2027 covers only expressly deferred new entries. Brussels time is the EU-wide display convention, not a carrier cutoff. Date-only changes use the calendar day in Europe/Brussels.
- Last reviewed
- 8 Nov 2026 — an editorial source check, separate from automatic timing.
- Official source
- Open the primary source ↗
The simple explanation
EUDR is the EU Deforestation Regulation. For the products it covers, businesses must be able to show that the relevant commodities were produced legally and without the deforestation prohibited by the regulation. Wood also has a forest-degradation condition. The land-use cutoff is 31 December 2020.
It covers listed products linked to cattle, cocoa, coffee, oil palm, rubber, soya and wood. That can matter to an online shop selling chocolate, coffee or wooden goods, but the commodity name alone does not establish scope. Match the exact product, materials and EU commodity code to Annex I, including its exclusions.
This is a supply-chain evidence requirement. A product identifier helps identify an item; it does not replace the production, traceability and due-diligence information required by EUDR.
A simple example
A UK shop sells roasted coffee beans to EU customers. Coffee under heading 0901 is already listed. The shop should establish who imports and first places the goods on the EU market, which operator deadline applies, and how the required evidence and references reach that business and its declarant.
The same shop also sells soluble coffee extracts under 2101 11 00. This is a newly added entry with a specific 30 December 2027 application date. That later date does not postpone the rules for the roasted coffee. One shop can need different preparation dates for different products.
What should a UK business do now?
- Check the catalogue. Record the code, materials and relevant Annex I entry for each potentially affected product. Include the reason for any exclusion.
- Agree who does what. Identify who imports and first places the goods on the EU market, who carries out due diligence and who submits any required statement. A UK business can itself have operator responsibilities; do not assume the carrier takes them over.
- Ask suppliers for evidence early. Establish what production and traceability information is available, including production locations where required. A general sustainability claim is not a substitute for the applicable evidence.
- Record the right deadline. Confirm the product-specific date and whether the operator actually qualifies for the later micro/small date. A small parcel value does not itself prove exemption.
- Test the information handover. Make sure the applicable due-diligence statement reference or simplified declaration identifier reaches the people who need it. For affected imports, confirm with the declarant what must be available before the customs declaration is lodged.
Not every retailer must submit a fresh due-diligence statement. Operators, qualifying micro or small primary operators, downstream operators and traders have different responsibilities. Confirm your actual role and process before choosing a reporting route.
Keep the dates separate
- 30 December 2026: the main EUDR application date. Do not assume that being a small online retailer automatically moves your obligations to June.
- 30 June 2027: the later date for operators qualifying under Article 38(3), including the condition that they were established as the relevant micro or small undertaking by 31 December 2024. Products covered by the EU Timber Regulation Annex are excluded from this extension. Check the statutory test, not just your current staff numbers or turnover.
- 30 December 2027: the specific deferred date for newly added product entries expressly marked with that date, including the coffee extracts and specified soaps below.
- 18 September 2026: the September product-list amendment entered into force. This is separate from the dates when the shipment and market obligations apply.
Older timber stock has separate transitional provisions in Article 37. Check those where relevant rather than treating the dates above as a complete rule for every timber consignment.
What has the EU published?
Regulation (EU) 2026/2102, published on 17 September 2026, changes Annex I of the EU Deforestation Regulation (EUDR). This annex is the legal list of covered products. It adds certain products, removes others and clarifies exclusions.
For UK retailers, the practical task is to compare the actual product and its EU commodity code with the updated list. A broad description such as “coffee”, “leather” or “wood” is not enough.

Examples worth checking
- Soluble coffee: coffee extracts, essences and concentrates under 2101 11 00 are added, with application from 30 December 2027. This does not move the date for coffee already covered by EUDR.
- Certain palm-oil-based soaps: specified products under ex 3401 11 00 and ex 3401 20 are added from 30 December 2027. Check the ingredients and legal exclusions; not every soap is covered.
- Specified cattle hides and leather: entries ex 4101, ex 4104 and ex 4107 are removed. This is not a statement that every product described as leather was previously covered.
- Some used wood products: the revised entries expressly exclude used or second-hand products, including under the wooden tableware and kitchenware entry ex 4419. Check the individual entry rather than assuming a blanket exemption for all second-hand goods.
“Ex” means only part of the classification is covered. The amendment contains other changes, including specific rubber products and palm-oil derivatives; these examples are not the full list.
Does the outer parcel packaging count?
The revised wood and paper entries distinguish packaging sold as a product from packaging used exclusively to support, protect or carry another product and presented with it. An outer carton protecting the order is not the same as selling cartons as the order itself. Follow the conditions in the relevant entry.
The amendment also excludes narrowly defined samples and testing goods. Simply writing “sample” on a normal sale does not qualify: the legal conditions cover value, quantity, permitted use and, for testing, what happens to the goods afterwards.
Entry into force of the amendment does not make all EUDR shipment obligations apply on 18 September. Equally, the later date for newly added products is not a postponement for goods already covered.
Northern Ireland and Great Britain
EUDR applies in Northern Ireland; it does not apply to the domestic Great Britain market. Selling from Great Britain into the EU or Northern Ireland still needs the relevant destination and supply-chain checks.
For Great Britain-to-Northern Ireland movements, also read the separate Northern Ireland parcel guidance. Do not assume that the EU import process and the UK Carrier Scheme are identical.
Official sources
- Current consolidated EUDR: scope, roles, Articles 37–38 and Annex I ↗
- Regulation (EU) 2025/2650: operative deadline and responsibility amendments ↗
- Regulation (EU) 2026/2102: full amendment and product entries ↗
- European Commission: EUDR overview and application dates ↗
- European Commission: implementation and non-EU suppliers ↗
- European Commission: identify your supply-chain role ↗
- European Commission: due diligence and customs references ↗
Updates to this article
Expanded the existing product-scope briefing into a preparation guide for online sellers, with a simple explanation, worked coffee example and supplier/data checklist. Rechecked current legislation and Commission guidance, clarified the Article 38(3) establishment condition and timber exception, and kept the selected December 2027 entries separate from the main December 2026 start. Original Published date, URL and image preserved.