EUDR explainer
EUDR: who is in scope on 30 December 2026 vs mid-2027, and what records to keep
Split the deadline. 30 December 2026: medium, large, and small operators already covered by EUTR (wood). 30 June 2027: micro and small operators outside EUTR. Dates below come from Commission and EY pages, not a video.
This page paraphrases public Commission and EY pages opened for this explainer. It is not legal advice and does not decide your role (operator, downstream operator, trader) or whether a SKU is a relevant product.
Live listing: apps.shopify.com/eudr-records-manager. The app stores lot and DDS records you enter. It 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
| 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 your entity size, establishment date, and Annex I product. This page does not assign you a role.
What records to keep
Access2Markets 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 this explainer does not decide
- 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.
Those are legal facts. Confirm them against the live regulation and counsel, not this page.
Install, register the first lot, keep the five-year map
If you already receive a DDS reference or declaration identifier, the catalog job is to store it against the lot before you need it.
- 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.
The app stores records you enter. It does not file a statement, obtain a new reference, or replace the EU information system. This page does not add prices. Confirm the live listing.
What this page is not
- 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. 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. This page is not legal advice.
When does EUDR apply for micro and small operators?
Micro and small operators outside EUTR apply from 30 June 2027. 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 this page come from those public pages, not a YouTube video. Confirm the live articles for your role and product. This page 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. Downstream actors collect and retain the reference. A lot registry records the number you received. It does not submit a statement.
Where do I store lot-to-DDS records for the catalog?
EUDR Records Manager is the App Store listing this site already uses to store supplier lots, DDS reference numbers or declaration identifiers per product, and a gap review for missing fields. It does not file a statement or decide your role. Confirm the live listing. This page is not legal advice.
Related pages
- 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
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.