Determine EUDR scope for a product, classify the entity as operator, trader or downstream operator, and identify which application date and country-risk category apply

Documented steps

1. Match the product's CN/HS code against Annex I of Regulation (EU) 2023/1115 to confirm it falls under one of the seven commodities: cattle, cocoa, coffee, oil palm, rubber, soya, wood.
2. Classify the entity under Article 2: operator (first places the relevant product on the EU market or exports it), trader (makes it available downstream without changing the CN/HS code), or downstream operator (processes it into a product with a different CN/HS code).
3. Determine company size (large or medium versus micro or small) because the application date differs.
4. Apply the dates set by Regulation (EU) 2025/2650: 30 December 2026 for large and medium enterprises, traders and downstream operators, and for micro/small enterprises on products already covered by the EUTR; 30 June 2027 for natural persons and micro/small enterprises on the remaining products.
5. Look up the country or region of production in the Commission's country benchmarking classification (Article 29) to obtain its low, standard or high deforestation-risk category.
6. Plan for the verification-check intensity tied to that category: broadly 9% of consignments for high risk, 3% for standard, 1% for low.
7. If classified as an operator, plan a full due diligence exercise (information gathering, risk assessment, risk mitigation) and a due diligence statement filed before placing the product on the market or exporting it.
8. If classified as a trader that does not change the CN/HS code, plan only to retain the upstream operator's DDS reference number rather than filing a new statement.
9. Check the Commission guidance and FAQ hub for edge cases: products produced before the application date, and the simplified regime for micro or small primary operators in low-risk countries.
10. Re-check Annex I before each submission cycle; a 2026 simplification package proposed adding products such as palm-oil soap and instant coffee.
11. Official sources verified 2026-08-03: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32023R1115 | https://green-forum.ec.europa.eu/nature-and-biodiversity/deforestation-regulation-implementation/roles-and-responsibilities_en | https://green-forum.ec.europa.eu/nature-and-biodiversity/deforestation-regulation-implementation/information-system-deforestation-regulation_en