EUDR is the shorthand every European food buyer now uses for Regulation (EU) 2023/1115 on deforestation-free products. It changes what an importer has to know about the land a raw material grew on, and it does so in a way that no previous food regulation has attempted. This guide explains what EUDR covers, what it does not cover, and what a food importer should actually verify with a supplier in Vietnam.
It is written for European importers, distributors, private-label brands and their sourcing teams, and for exporters who supply them. Dates and thresholds have already moved more than once, so treat every timing statement below as a pointer and confirm the current position on the European Commission’s own pages before you build a plan around it.
What EUDR is and why food importers care
The regulation makes it unlawful to place certain commodities and products on the European Union market, or to export them from it, unless three conditions are met at once. The goods must be deforestation-free, they must have been produced in accordance with the relevant legislation of the country of production, and they must be covered by a due diligence statement.
Deforestation-free has a fixed reference date rather than a rolling one. The land the commodity grew on must not have been deforested after 31 December 2020, and for wood there is an additional requirement that harvesting did not cause forest degradation. That cut-off is the single most important number in EUDR because it converts a general sustainability aspiration into a testable fact about a specific plot of land.
EUDR replaced the older EU Timber Regulation approach and extended it well beyond wood. It applies to the operator who first places a product on the market and, in a modified way, to traders further down the chain. The official starting point for any research is the European Commission’s deforestation-free products page, which hosts the legal text, the guidance and the frequently asked questions.
Which commodities EUDR actually covers
This is where most food buyers relax and then make a mistake. EUDR covers seven commodities and the products derived from them, and the derived products are listed in Annex I of the regulation by customs code. Fruit, vegetables, nuts, spices and herbs as such are not on the list.
| Commodity in scope | Typical food relevance | Where it hides |
|---|---|---|
| Cattle | Beef, tallow, leather | Rendered fats, gelatine inputs |
| Cocoa | Chocolate, cocoa butter, cocoa powder | Coatings and inclusions |
| Coffee | Roast and instant coffee, extracts | Blends and flavour bases |
| Oil palm | Palm oil and palm kernel derivatives | Frying oil, emulsifiers, anti-caking, glazing |
| Rubber | Natural rubber articles | Seals, gaskets, gloves in some product lines |
| Soya | Soybean oil, meal, lecithin | Lecithin as an emulsifier in coated products |
| Wood | Timber, pulp, paper, board | Cartons, pallets, printed packaging |
So a container of IQF mango, dried banana or black pepper is not in the EUDR scope on account of the fruit or spice itself. The exposure arrives through ingredients and materials that ride along with it. That distinction is worth writing down clearly for a procurement team, because a blanket assumption in either direction causes problems.
Where EUDR touches a fruit, vegetable and spice supply chain
A useful way to run the analysis is to take the finished article that will be sold in Europe and list every input, not just the headline ingredient. Then check each input against the Annex I code list rather than against a mental picture of what EUDR is about.
- Palm derived oils used for frying, coating, roasting or as a release agent.
- Palm derived emulsifiers, anti-caking agents and glazing agents in powders and coated fruit.
- Soya lecithin in coatings, compound chocolate and some seasoning carriers.
- Cocoa or coffee inclusions in a snack or beverage formulation.
- Wood, pulp and paper items where the paper product is itself the traded good.
- Any commodity blended in at a low percentage, since EUDR has no de minimis threshold by weight.
The absence of a general de minimis threshold is the detail that catches people. There is no 1% or 0.5% carve out by weight, so a small inclusion of an in-scope commodity can bring a product into EUDR scope if the finished product sits under an Annex I code. Check the code of the finished article, not the proportion of the ingredient, and confirm the current Annex I list because it has been the subject of amending acts.
For a supplier of plain fruit, vegetables and spices, the practical answer is usually short. Products on the IQF frozen and spices and herbs ranges are typically outside the commodity list, and the honest response to a buyer questionnaire is a clear statement of that fact with the reasoning attached rather than a certificate that does not exist.
EUDR timelines and what they mean for planning
The regulation entered into force in June 2023 with an original application date of 30 December 2024. That date was postponed by a year, and then postponed again. As this guide is written the amended position is that the main obligations apply from 30 December 2026 for large and medium operators and traders, and from 30 June 2027 for micro and small enterprises.
In May 2026 the Commission published a package of simplification measures, updated guidance and a draft act on product scope, and indicated that the text itself would not be reopened. The sensible planning assumption is therefore that EUDR arrives on the amended dates rather than that another delay will follow. Verify the current dates directly before committing to a supplier programme.
For a food importer the practical consequence is that supplier engagement has to start well before the application date. Collecting geolocation data from a farm base takes a season, not a week, and a supplier who has never been asked for a polygon will not produce one by return of email.
The three EUDR tests in plain language
Every obligation in the regulation reduces to three questions asked about a specific consignment. Keeping them separate makes the paperwork much easier to organise.
| Test | Question | Evidence usually needed |
|---|---|---|
| Deforestation-free | Was the land forest after 31 December 2020? | Plot geolocation plus satellite or land use verification |
| Legality | Was production lawful in the country of origin? | Land tenure, labour, tax, trade and environmental compliance evidence |
| Due diligence | Has risk been assessed and mitigated? | Information collection, risk assessment, risk mitigation records |
The legality test is broader than most buyers expect. It reaches land use rights, environmental protection, forest related rules, third party rights, labour rights, human rights protected under international law, the principle of free prior and informed consent, and tax, anti-corruption, trade and customs regulations. It is a compliance test about the country of production, not only a deforestation test.
Geolocation data: what EUDR expects from a supplier
Operators have to collect the geographic coordinates of all plots of land where the commodity was produced, together with the date or time range of production. A single point is acceptable for very small plots, while larger plots require polygons. This is the requirement that changes daily life at origin more than any other part of EUDR.
Three practical problems follow. Smallholder supply chains involve thousands of plots rather than dozens. Aggregators and collection points break the link between a lot and a plot. Data protection and commercial sensitivity make some suppliers reluctant to release farm coordinates to a buyer who may pass them on.
The workable answer is a traceability system built at origin, with lot codes that resolve back to a recorded set of plots, and a written agreement about how the coordinates may be used. Our sustainability page sets out how traceability is handled across the Greatfoods supply base.
The due diligence statement and the EU information system
Before placing an in-scope product on the market, the operator submits a due diligence statement through the information system the Commission operates for this purpose. The statement carries a reference number, and downstream operators and non-SME traders refer to those numbers in their own statements so the chain remains traceable.
Submitting a statement is a legal assertion, not an administrative formality. By submitting it the operator assumes responsibility for the compliance of the product. That is why the internal file behind each EUDR statement matters more than the statement itself: information collected, risk assessed, risk mitigated, and the reasoning recorded so it can be inspected later.
Country benchmarking and simplified due diligence
EUDR classifies countries of production as low, standard or high risk. The classification changes the work required rather than the legality of trade. For commodities from a low risk country, operators may apply a simplified due diligence that requires information collection but not the full risk assessment and mitigation steps.
Two cautions apply. Country risk classification can be reviewed and changed, so a process built entirely on a low risk assumption is fragile. And simplified due diligence still requires the geolocation and legality information to be collected, so it reduces the analysis rather than removing the data burden.
Operators, traders and who carries the obligation
The regulation distinguishes the operator, who first places the product on the EU market or exports it, from the trader, who makes it available further down the chain. Large and medium traders carry obligations close to those of an operator. Small and micro traders mainly have to keep records of who they bought from and who they sold to.
For a Vietnamese exporter this matters because the operator is almost always the EU importer, not the supplier at origin. The supplier’s role under EUDR is to provide reliable information, not to submit statements. A supplier who claims to be EUDR certified has misunderstood the structure, because the regulation creates no certification scheme.
That said, several voluntary schemes and origin verification services now market themselves as EUDR aligned. They can be useful evidence inside a risk assessment. They do not transfer the legal responsibility, which stays with the operator.
What to ask a Vietnamese supplier about EUDR
A focused questionnaire gets better answers than a generic sustainability form. The list below covers what an EU operator actually needs on file for a food product from Vietnam.
- A written statement of whether any Annex I commodity is present in the product or its recipe.
- The customs code of the finished article, checked against the current Annex I list.
- For in-scope inputs, the country of production and the plot geolocation data.
- The production date or time range associated with each plot.
- Evidence of lawful production, including land use rights and labour compliance.
- A description of how lot codes trace back to the recorded plots.
- Confirmation of who the operator will be and who submits the statement.
- A statement on packaging materials and whether any wood or paper item is a traded good.
Keep the questionnaire proportionate. Sending a full EUDR pack to a supplier of dried lemongrass wastes both sides’ time and dilutes the attention available for the inputs that genuinely sit in scope. Screening first, then depth where it is warranted, is the pattern that works.
Packaging, pallets and the wood question
Wood is in scope, and food ships in cartons on pallets, so buyers reasonably ask where EUDR stops. The Commission’s guidance addresses packaging material used exclusively as packaging support for another product, and treats it differently from paper and wood products that are themselves the goods being traded.
Because this specific point has been clarified through guidance rather than through the original text, it is one to verify at the time of shipment rather than to assume from a summary. Wood packaging also carries a separate and unrelated plant health obligation covered in our guide to phytosanitary certificates for food export.
Penalties and the commercial risk of getting EUDR wrong
Member States set penalties, and the regulation requires them to be effective, proportionate and dissuasive. It specifies fines proportionate to environmental damage and to the value of the commodities, with a maximum of at least 4% of the annual EU turnover of the operator or trader, alongside confiscation of goods and revenues and temporary exclusion from public procurement.
Scale that against a normal food shipment. A single container carrying 20 tons to 25 tons of product is a small exposure next to a penalty calculated on 4% of group turnover, which is precisely why the regulation is drafted that way. The deterrent is aimed at the operator’s balance sheet rather than at the value of the consignment.
The commercial risk usually arrives earlier than the legal one. Retail customers write EUDR obligations into supply agreements ahead of the application date, and a supplier who cannot answer a screening questionnaire loses the listing long before any authority becomes involved. Treat the questionnaire as a commercial document, not a compliance chore.
How EUDR fits with the rest of your compliance file
EUDR sits alongside the food safety and customs work that already exists rather than replacing any of it. The three files draw on the same underlying supplier information, which is why building them together is far cheaper than building them one at a time.
- Customs classification, which decides whether a finished article sits under an Annex I code.
- Food safety certification, which evidences the management system behind the supplier claim.
- Phytosanitary documentation, which covers the plant health route into the market.
- Certificates of analysis, which evidence the product specification lot by lot.
- Social and ethical audits, which overlap with the EUDR legality test on labour.
Read this page together with our guides to HS codes for Vietnamese food exports and food safety certifications. Trade flow and market access context can be checked on Access2Markets and ITC Trade Map while you build the file.
Frequently asked questions about EUDR
Does EUDR apply to frozen fruit and vegetables?
Not on account of the fruit or vegetable itself, because those commodities are not on the EUDR list. A frozen product can still be caught if it contains an in-scope input such as a palm derived ingredient and the finished article falls under an Annex I code, so screen the recipe rather than the category.
Can a supplier be EUDR certified?
No. The regulation does not create a certification scheme. Suppliers can hold voluntary scheme certificates that support a risk assessment, but the legal obligation to submit a due diligence statement stays with the operator placing the goods on the EU market.
What geolocation format does EUDR require?
Coordinates in a stated reference system, with polygons for larger plots and a single point acceptable for very small ones, together with the production date or time range. The information system defines the accepted file formats, so confirm the current technical specification before collecting data at scale.
Does EUDR replace organic or GLOBAL G.A.P. certification?
No. Those schemes address production standards and food safety assurance. EUDR addresses deforestation, legality and due diligence. A GLOBAL G.A.P. certificate can be useful evidence inside a risk assessment but it is not a substitute for the statement.
When should we start collecting supplier data?
Now, if any input sits in scope. Geolocation collection follows the agricultural calendar and depends on cooperation from growers and aggregators, so a programme started a few months before the application date is already late.
Bottom line on EUDR for food importers
Screen the recipe and the customs code first, because most fruit, vegetable, nut and spice lines fall outside the commodity list entirely. Where an in-scope input is present, start collecting geolocation and legality evidence early, keep the reasoning file behind each statement, and confirm the current application dates and Annex I scope on the Commission’s own pages rather than from a summary. To discuss product composition, traceability or documentation, browse the product range, see our packaging solutions page or contact Greatfoods.
Greatfoods is a manufacturer, exporter and supplier of high-quality food and beverage ingredients from Vietnam, including IQF frozen fruits and vegetables, dried and soft-dried fruit, nuts, spices and herbs, powders and flours, and NFC juices, purees and concentrates. We supply importers, distributors, foodservice operators and private-label brands worldwide with certified quality (HACCP, IFS, BRC, GLOBAL G.A.P., ISO, HALAL, SEDEX) and complete export documentation.