EUDR: THE NEW ORIGIN TRACEABILITY ARRIVING AT EUROPEAN CUSTOMS

The European Union's Deforestation Regulation (EUDR) will require companies to demonstrate that certain raw materials and derived products do not originate from deforested land after December 31, 2020. From December 30, 2026, this requirement will fully affect importers, exporters, and logistics chains linked to coffee, cocoa, timber, rubber, soy, palm oil, beef, and derived products.

Traceability is no longer voluntary

For years, traceability in sectors like coffee, cocoa, timber, and rubber was associated with certifications, internal sustainability policies, or demands from major clients. With the EUDR, traceability becomes a regulatory requirement for accessing the European market.

The European Regulation against Deforestation establishes that certain products cannot be introduced into the European Union market or exported from it unless it is demonstrated that they are deforestation-free and have been produced in accordance with the applicable legislation in the country of origin. The novelty lies not only in requiring more documentation but also in the level of precision required. Knowing the country of origin or the commercial supplier is no longer sufficient. In many cases, it will be necessary to identify the exact plot of land where the raw material was produced.

Implementation is scheduled for December 30, 2026, for large and medium-sized operators. For micro and small businesses, the general deadline is extended to June 30, 2027, except in some cases related to products already covered by the previous Timber Regulation. The timeframe seems generous, but in international supply chains with multiple suppliers, mixed batches, and scattered documentation, 2026 is already a year of operational preparation.

Which products are affected?

The EUDR covers raw materials specifically linked to agricultural expansion into forested areas: cattle, cocoa, coffee, oil palm, rubber, soybeans, and timber. It also affects certain derived products included in Annex I of the regulation, defined by tariff codes.

This means that the impact is not limited to importers of raw materials. It can affect companies that trade in chocolate, roasted coffee, furniture, paper, leather, tires, wood products, industrial ingredients, or manufactured goods that incorporate regulated raw materials. The first question a company should ask itself is not just whether it buys coffee, cocoa, or timber, but whether the specific product it imports or exports falls within the codes covered by the regulation.

The key date is December 31, 2020. To be considered deforestation-free, the product must originate from land that has not been deforested after that date. In the case of wood products, it must also be demonstrated that they have not caused forest degradation after that temporary harvesting.

Under the EUDR, the supplier not only sends goods; they must also send reliable data about the actual origin of those goods.

A Global Problem with a Direct Impact on Trade

The scale of the problem explains why the European Union has made deforestation a trade issue. According to the FAO, forests currently cover some 4.14 billion hectares, nearly a third of the Earth's land surface. Although deforestation has slowed compared to previous decades, between 2015 and 2025, an estimated 10.9 million hectares will still be lost annually due to deforestation. The net annual loss of forest area was 4.12 million hectares during that same period.

The European Commission estimates that the EUDR should contribute to reducing carbon emissions linked to European consumption and production of covered raw materials by at least 32 million tons per year. But for businesses, the most immediate consequence will be practical: without due diligence, traceability, and a valid declaration, goods can be blocked from a trade and customs perspective.

From the Farm to the Customs File

The EUDR introduces a documentary logic that begins long before transport. The company must collect information on the product, the supplier, the quantity, the country of production, the geographical origin, the legality of production, and the absence of deforestation. In complex operations, this information must be linked to specific batches and kept available for audits.

One of the most relevant elements is geolocation. For agricultural products from various farms, cooperatives, or collection centers, the company must be able to link the product to the plots of origin. This is especially critical in supply chains where there is a mix of goods, as can occur with coffee, cocoa, soybeans, or natural rubber.

The due diligence declaration will be submitted through the EUDR Information System. This system allows operators, traders, and representatives to generate and manage electronic declarations, including data such as HS code, product description, quantity, and origin. In practice, the EUDR information must be coordinated with commercial, logistics, and customs documentation.

For the logistics department, this changes the usual process. While previously some documents could be completed during transit or shortly before shipment, now the origin information must be validated before the goods reach the critical point. A container without sufficient traceability data can become a problem for shipping, compliance, and sales.

Traceability will no longer accompany the logistics operation: it will be part of the operation's very viability.

Country Risk Does Not Eliminate Obligations

The European Commission has established a country classification system based on the risk that raw materials covered by the EUDR are not deforestation-free. The categories are low risk, standard risk, and high risk. This classification influences the intensity of controls by the competent authorities: 1% for low risk, 3% for standard risk, and 9% for high risk.

The classification helps to modulate due diligence, but it does not replace traceability. In low-risk countries, certain obligations may be simplified, but companies still need to collect information. Furthermore, the system is dynamic and subject to review. Basing an entire strategy on a country maintaining a specific category would be risky.

For an importer, the message is clear: geographical origin matters, but responsibility does not disappear by purchasing from a country considered low risk. The documentation must be able to withstand a review.

Coffee and Cocoa: Two Closely Related Examples

The current state of the EUDR is best understood through trade figures. In 2024, EU agri-food imports reached a record €171.8 billion, 8% higher than in 2023. The European Commission attributed much of this increase to rising prices for cocoa, coffee, fruit, and nuts.

Cocoa is a particularly clear example. The value of European imports of cocoa products, including beans, paste, butter, and powder, rose from €7 billion in 2023 to €13.5 billion in 2024. The Commission notes that 81% of European cocoa imports came from sub-Saharan Africa. For coffee, EU imports reached €13.6 billion in 2024, 28% higher than in 2023, with Brazil as the main source, accounting for 36%.

Spain is also directly affected. According to the European Coffee Report 2024-2025, Spain was the fourth largest importer of green coffee in the EU in 2024, with 258,740 tons, representing 8.9% of the European total. Regarding cocoa, WITS/UN Comtrade data compiled by the World Bank indicate that Spain imported approximately 103,986 tons of cocoa beans in 2024, valued at $538.2 million, with Ivory Coast, Nigeria, Ecuador, Peru, and Ghana among its main sources.

This data shows that the EUDR is not a distant regulation for large international traders. It affects supply chains that are very much present in Spanish consumption, the food industry, distribution, and logistics.

Preparing Before Shipping

In May 2026, the European Commission published simplification measures that, according to its estimates, could reduce annual administrative costs by around 75% compared to the initial design. Even so, the simplification does not eliminate the core of the standard: demonstrating that the product is deforestation-free, legal at origin, and traceable.

Preparation should begin by identifying the affected products and their tariff codes, reviewing supplier contracts, requesting geolocation data, defining internal responsibilities, and linking due diligence to the logistics record. It will also be necessary to decide who acts as the operator, trader, or representative, and what information each part of the supply chain must retain.

The EUDR makes traceability a condition of market access. For companies that import or export regulated products, the advantage will lie in anticipation. In 2026, moving goods will still be essential, but it will no longer be enough: verifiable, consistent, and available data will also need to be moved before the transaction reaches customs.

Sources for further information:

• European Commission, official website of the Regulation on deforestation-free products: objectives, scope, raw materials covered, 2026-2027 timetable, and estimated emission reductions. (Environment)

• EUR-Lex, consolidated version of Regulation (EU) 2023/1115: definition of relevant raw materials, relevant products, and cut-off date of 31 December 2020. (EUR-Lex)

• European Commission, Green Forum, implementation of the EUDR: practical obligations, due diligence, and roles of operators and traders. (Green Forum)

• FAO, Global Forest Resources Assessment 2025: global forest area, rate of deforestation, and net forest loss. (FAOHome)

• European Commission, Monitoring EU Agri-Food Trade 2024: EU agri-food imports, trends in cocoa and coffee, import value, and main regions of origin. (Agriculture and rural development)

• European Coffee Federation, European Coffee Report 2024-2025: data on green coffee imports in Spain and its share of the EU total. (ECF)