A few weeks ago, an importer told me on the phone: "EUDR? That's a sustainability thing. My supplier has a certificate, we're fine."
I understand the reflex. After two postponements, many companies have put the subject in a drawer. But this time the date is firm: 30 December 2026 for large and medium-sized companies, 30 June 2027 for micro and small ones. The Commission has said it plainly: there will be no third postponement.
And above all, here is what I would like you to take away from this article: for you as an importer, EUDR is not a CSR topic. It is a condition for customs clearance.
What will really happen at the border
Coffee, cocoa, soy, timber, rubber, cattle, palm oil, and many of their derived products (chocolate, leather, furniture, paper, tyres…) will no longer be allowed onto the EU market, or out of it, without three things:
- proof that they are "deforestation-free": no plot cleared after 31 December 2020;
- proof that they were produced legally in the country of origin;
- a due diligence statement, filed in the EU Information System, with its reference number.
That number is what matters. It has to be available at the moment of clearance. If it is missing, or if the risk analysis triggers a check, customs can suspend release. In practice: your container stays at the port, the storage meter runs, and your customer waits.
What the late-2025 revision changed (and what it did not)
I mention this because I often hear "anyway, they've relaxed everything". That is partly true. Amending Regulation (EU) 2025/2650 brought two real simplifications:
- if you are a downstream operator or a trader buying products already covered by a statement, you no longer have to carry out full due diligence again, but you must keep your suppliers' information for five years;
- if you are a micro or small primary producer, a simplified statement is possible.
But nothing has moved on the essentials: geolocation of plots remains mandatory, the 31 December 2020 cut-off remains, and penalties can reach at least 4% of your EU turnover. If you are a medium or large company placing the product on the market first, full due diligence is for you.
One point I am watching for my clients: in May 2026 the Commission put out for consultation a draft that would change the product list (adding instant coffee and certain palm-oil derivatives, removing leather among others). If you are in those supply chains, your CN codes deserve a second check before you build your files.
The four mistakes I come across most often
"My supplier takes care of it."
This is the sentence I hear most, and the one that worries me most. Responsibility lies with whoever places the product on the EU market, meaning you. A sustainability certificate, however serious, does not replace your due diligence statement.
No geographic coordinates.
For coffee or cocoa sourced from hundreds of smallholders, collecting geodata takes weeks, sometimes months. It is bottleneck number one. If you have not asked for them yet, that is the first email to send today.
Approximate CN codes.
The scope of EUDR follows the Combined Nomenclature. A slightly loose tariff classification can make you miss an obligation… or create one that does not exist. I have seen both.
An EUDR file prepared in isolation.
The invoice, the origin, the CN code, the EUDR reference number and what your forwarder receives must all tell the same story. A single inconsistency is enough to trigger a check. This is exactly where I spend the most time with my clients.
A case I supported
An importer of African timber contacted me while his supplier was sending documents in every direction, with no one knowing what was actually missing. We took the file back before shipment: checked the CN codes concerned, aligned the supplier's documents with the geolocation data, and drew up a clear list of what remained to be obtained. His forwarder received a complete file, and clearance went through without any back-and-forth.
What made the difference was not some out-of-reach expertise. It was looking at customs and EUDR together, and before the container left.
Where to start, this week
- List your products and their CN codes, and check which ones fall within EUDR.
- Determine your role (operator, downstream operator, trader) and your company size.
- Ask your suppliers for geodata and proof of legality, batch by batch.
- Register in the EU Information System.
- Agree with your declarant how the reference number will be passed on.
Let's talk about your situation
I work every day with importers and exporters between Europe and Brazil, often in Portuguese with their suppliers, and I know how hard it is to get the right documents at the right time. My role is to prepare, upstream, a ready-to-file dossier that brings together customs and EUDR requirements, then hand it to your forwarder or declarant.
CTB Group is not a customs representative and does not lodge declarations on behalf of third parties: we work upstream, and the declaration remains lodged by your licensed declarant.
Is your next shipment arriving after 30 December? Write to me or book a free first 30-minute conversation. Together we will look at which products are concerned and what is missing from your files. You will leave with a clear list, whatever happens next.
Premier échange offert (30 min)
And if you have already started your EUDR preparation, tell me where it is getting stuck: it is often the same place for everyone, and it helps me write the next articles.