EU Deforestation Regulation (EUDR)
What Shippers Need to Know About the EUDR
The EUDR is a new environmental regulation that will apply across the European Union (EU) as of 30 December 2026. It imposes due diligence requirements on importers and exporters, and other operators or traders, to ensure that commodities and products in their supply chains are deforestation-free and produced in accordance with the relevant legislation of the country of production.
To avert costly interruptions of import and export shipments at customs clearance it is key that shippers understand their role and responsibilities and take early actions to provide DHL timely with the necessary EUDR information.
What Products Are in Scope
All relevant goods are specified by good descriptions and 4-to-6-digit customs classification codes in Annex I of the EUDR. They include listed commodities, such as palm oil, cattle, soy, coffee, cocoa, timber, wood, rubber, and listed products derived from or containing one or more listed commodities (“EUDR goods”). Certain exemptions (e.g., waste or second-hand products) may apply based on the nature of the goods and their customs classification.
What Kind of Obligations Could Apply
All parties in the supply chain having the legal status of an Operator or Trader and particularly those intending to import or export EUDR goods must comply with applicable EUDR requirements. These may include following obligations, among others:
- The timely provision of Due Diligence Statement Reference Number(s) or Declaration Identifier(s)¹ for individual EUDR good(s) and/or any other necessary EUDR information required for compliance with the EUDR along the supply chain, including EUDR-specific TARIC codes for customs declarations.²
- The implementation of a due diligence, record keeping, and reporting system for relevant checks and mitigation of identified risks associated with EUDR goods.
- Where required, registration requirements and/or the submission of Due Diligence Statement(s) or one-time Simplified Declaration(s)¹ to the national competent authorities in the EU member states through the central EU information system TRACES.
What Does DHL Need From Shippers for Import and Export Customs Clearance
Every EUDR good imported into the EU or exported out of the EU must be covered by a Due Diligence Statement Reference Number(s) or Declaration Identifier(s)¹ and/or TARIC codes, which shippers must share with DHL prior to lodging the respective customs declaration. Otherwise, customs authorities will likely not release EUDR goods at the external EU border. Providing correct and complete EUDR information early to DHL helps avoid delays and supports compliant customs clearance.
Four Steps to Prepare for the EUDR
Step 1: Check Whether Your Products Are in Scope
The EUDR covers the following commodities and certain products made from or containing them:
- cattle
- wood
- coffee
- cocoa
- soy
- palm oil
- natural rubber
Products in scope are identified by their goods descriptions and customs classification codes in Annex I of the EUDR. There is no exemption based solely on the quantity or value of the goods.
The EUDR may apply to both B2B and B2C commercial transactions where relevant products are placed on the EU market or exported from the EU. Products sent solely for private use in a non-commercial transaction are outside the scope.
Certain exclusions or exemptions may apply, including for:
- Packaging used only to support, protect or carry another product
- Samples and products used for examination, analysis or testing
- Used or second-hand products
- Products made entirely from waste or recovered material
- Items of correspondence
Step 2: Determine Your EUDR Responsibilities
Identify your role in the supply chain (operator, trader, micro and small primary operator, downstream operator) and determine which EUDR requirements apply to your business.
Depending on your role, you may need to:
- Carry out due diligence
- Collect product and supply-chain information
- Register in the EU EUDR Information System
- Submit a Due Diligence Statement or, where applicable, a Simplified Declaration
- Keep the required records
- Obtain the EUDR information needed for customs clearance
Useful guidance for the determination of your company size includes the following:
- Role: EUDR Implementation Website
- Company Size: Article 3 of Directive 2013/34
Step 3: Obtain the Applicable EUDR Data Element
Every shipment affected by the EUDR must include the applicable EUDR data element.
Depending on the goods and your role, this may be:
- A Due Diligence Statement Reference Number
- A Simplified Declaration Identifier, where applicable
- A Conventional Due Diligence Statement Reference Number for eligible transitional goods
- An applicable EUDR TARIC document code, including where an exemption applies
Step 4: Provide the Information to DHL Prior to Customs Clearance
Provide the applicable EUDR data element to DHL electronically at line-item level during shipment creation.
You should also provide:
- The correct Harmonized System code
- A clear and specific description of the goods
- Complete and accurate electronic shipment data
Useful Public Guidance On the EUDR
If you have legal questions or are uncertain about your EUDR obligations, consult the guidance published by the European Commission or seek advice from qualified external counsel.
Footnotes
(1) Simplified requirements will apply to small- or medium-sized enterprises (SME) only as of 1 July 2026
(2) See TARIC the codes of individual for database for all measures on the Common Customs Tariff (CCT) and commercial and agricultural legislation.