EUDR explainer

EUDR: who is in scope on 30 December 2026 vs mid-2027, and what records to keep

EUDR Records Manager (Shopify App Store) is a Shopify app that keeps a supplier and commodity-lot registry with DDS reference numbers per product, flags missing supplier, country or DDS fields, and retains an audit trail of supplier, lot, document and export changes. It does not file the due diligence statement in the EU information system.

Free check first: EUDR product scope check runs in your browser and sends nothing. Type a product or HS code and see which EUDR Annex I lines it may touch.

Split the EUDR deadline: medium, large, and small operators already covered by EUTR (wood) apply from 30 December 2026, and micro and small operators outside EUTR apply from 30 June 2027. Dates on the EUDR scope explainer come from Commission and EY public pages, not a video.

I resell coffee, cocoa or chocolate online — what does EUDR require of me?

Role first. This explainer is not legal advice and is not a role determination.

If you buy products already placed on the EU market and resell them, you are usually a trader (or a downstream operator if you make a new product from them, e.g. chocolate from cocoa).
If you import from outside the EU, you are the operator who files the due diligence statement.

What a reseller keeps, per Article 5 of Regulation (EU) 2023/1115 as amended by Regulation (EU) 2025/2650:

For five years: who supplied you and whom you supplied.
If your supplier is the operator who filed, you also keep the DDS reference number (or simplified-declaration identifier) you received. That collection duty sits with the first downstream operator or trader after that operator.

This block does not state a trader or downstream application date. Role and size decide the date — use the date table below, then confirm the live articles.

EUDR Records Manager stores supplier, country, commodity lot and the DDS reference or identifier you received, and runs a gap review. It does not file a statement or decide your role.

Install EUDR Records Manager

The EUDR scope explainer paraphrases public Commission and EY pages opened for the explainer. The explainer is not legal advice and does not decide operator, downstream-operator, or trader role, or whether a SKU is a relevant product.

Live listing: apps.shopify.com/eudr-records-manager. EUDR Records Manager stores lot and DDS records the merchant enters. The app does not file a due diligence statement.

Lot-registry how-to: store the DDS reference against each supplier lot. Adjacent: EU generic claims · CRA duty records.

Who is in scope on which date

Medium and large operators, small operators already covered by EUTR (wood), and — on Access2Markets — downstream operators and traders of all sizes apply from 30 December 2026, while micro and small operators outside EUTR apply from 30 June 2027. Confirm Regulation (EU) 2023/1115 as amended by Regulation (EU) 2025/2650 for entity size and Annex I product.

Application dates from Commission and Access2Markets pages opened for this explainer
Date	Who the public pages list
30 December 2026	Medium and large operators. Small operators already covered by EUTR (wood). Access2Markets also lists downstream operators and traders of all sizes on this date.
30 June 2027	Micro and small operators outside EUTR (products not in the EUTR annex).

Sources opened for those rows:

European Commission, DG Environment, Regulation on deforestation-free products — large and medium operators 30 December 2026; micro and small operators 30 June 2027; micro and small already covered by EUTR (wood) 30 December 2026.
European Commission, Access2Markets, Delay until December 2026 and other developments (28 January 2026) — same two dates, plus the downstream / trader / EUTR-annex split.
EY Tax News, EU Deforestation Regulation application postponed to 30 December 2026 (20 January 2026) — 30 December 2026 for large companies; 30 June 2027 for small and micro enterprises and natural persons, only for products not already covered by EUTR.

The legal texts those pages implement are Regulation (EU) 2023/1115 as amended by Regulation (EU) 2025/2650. Confirm the live articles for entity size, establishment date, and Annex I product. The EUDR scope explainer does not assign a role.

What records to keep

Access2Markets states that operators collect and retain, for five years, data on who supplied them and whom they supplied. Downstream operators and traders collect and retain the reference number of the initial due diligence statement or simplified declaration instead of filing their own. A catalog lot registry stores SKU or lot, supplier, country, and that reference or declaration identifier.

Access2Markets also states that, regardless of size, operators collect and retain for five years:

data of the operators, downstream operators, or traders who supplied the relevant products, and
details of the downstream operators or traders to whom they supplied those products.

The same page states that the due diligence statement is filed by the operators who first place the product on the market, and that operators and traders downstream collect and retain the reference number of the initial declaration (or the simplified-declaration identifier) instead of filing their own. Micro or small primary operators in low-risk countries submit a single simplified declaration (Annex III), not a per-shipment statement.

The ecommerce record that maps onto a catalog is:

product / SKU
supplier
country of production
commodity lot
DDS reference number
# or declaration identifier, if that is what you received

Keep that mapping so a later check can retrieve the number you were given. Filing in the EU information system is a separate act. Relevant commodities on the Commission page include cattle, wood, cocoa, soy, palm oil, coffee, rubber, and derived products such as leather, chocolate, tyres, or furniture. Annex I CN codes decide scope, not a storefront title.

What the EUDR scope explainer does not decide

The EUDR scope explainer does not decide whether a merchant is an operator, downstream operator, or trader, whether a SKU is a relevant product under Annex I, or whether a due diligence statement was validly submitted. Those are legal facts. Confirm them against the live regulation and counsel, not the EUDR scope explainer.

Whether you are an operator, downstream operator, or trader.
Whether a SKU is a relevant product under Annex I.
Whether a due diligence statement was validly submitted.

Install, register the first lot, keep the five-year map

If a merchant already receives a DDS reference or declaration identifier, the catalog job is to store the number against the lot before a later check needs it. EUDR Records Manager stores supplier lots and those references; the listing does not file a due diligence statement or replace the EU information system.

Open the EUDR Records Manager listing (apps.shopify.com/eudr-records-manager) and install it.
Record supplier, country, and commodity lot against the product, and store the reference or identifier you received.
Run a gap review for missing supplier, country, or DDS fields.
Keep the audit trail so a later review matches the source. Repeat when lots change.

EUDR Records Manager stores records the merchant enters. The app does not file a statement, obtain a new reference, or replace the EU information system. The EUDR scope explainer does not add prices. Confirm the live listing.

Install EUDR Records Manager

What the EUDR scope explainer is not

The EUDR scope explainer splits 30 December 2026 versus 30 June 2027 and names the five-year supplier and DDS records Access2Markets describes. The explainer is not legal advice, a role determination, a compliance certification, or a due diligence statement filing tool.

Not legal advice, a role determination, or a compliance certification.
Not a due diligence statement filing tool or access to the EU information system.
Not the lot-registry start path. That is DDS reference numbers on supplier lots.
Not the EU generic-claim copy job. That path is generic environmental claims from 27 September 2026.

When does EUDR apply for large and medium operators?

Split the deadline: medium and large operators, and small operators already covered by EUTR (wood), apply from 30 December 2026, and Access2Markets also lists downstream operators and traders of all sizes on that date. Confirm Regulation (EU) 2023/1115 as amended by Regulation (EU) 2025/2650; the EUDR scope explainer is not legal advice.

When does EUDR apply for micro and small operators?

Micro and small operators outside EUTR apply from 30 June 2027, while small operators already covered by EUTR (wood) stay on 30 December 2026. Access2Markets and EY’s 20 January 2026 tax alert describe that split; dates on the EUDR scope explainer come from those public pages, not a YouTube video. Confirm the live articles for role and product. The explainer is not legal advice.

What records should I keep under EUDR?

Access2Markets states that operators collect and retain, for five years, data on who supplied them and whom they supplied. Downstream operators and traders collect and retain the reference number of the initial due diligence statement or simplified declaration instead of filing their own. A catalog lot registry stores SKU or lot → supplier → country → that reference or declaration identifier. Filing the statement is a separate act in the EU information system.

Does keeping a DDS reference mean I filed a due diligence statement?

No: Access2Markets states that the obligation to submit the due diligence statement lies with the operators who first place the product on the market, and downstream actors collect and retain the reference. A lot registry records the number received and does not submit a statement.

Where do I store lot-to-DDS records for the catalog?

EUDR Records Manager is the App Store listing already used on momiji-space to store supplier lots, DDS reference numbers or declaration identifiers per product, and a gap review for missing fields. The listing does not file a statement or decide a role. Confirm the live listing. The EUDR scope explainer is not legal advice.

EUDR DDS lot registry — store the reference against each lot
EUDR Records Manager — live App Store listing
Commission EUDR page
Access2Markets delay note
EY 20 January 2026 alert
EU generic environmental claims ban
Shopify apps hub
Tools

Type a product or HS code into the free EUDR product scope check to see which Annex I lines to read.

Not legal advice. Not a compliance guarantee. Not a DDS filing. Confirm Regulation (EU) 2023/1115 as amended by Regulation (EU) 2025/2650, and the live Commission pages, before you treat a lot as in or out of scope. The app stores lot and DDS records you enter; you choose what to record.