EUDR Starts Dec 30, 2026: What Asian Suppliers Must Provide

Bottom line

The EU importer files the statement, but only the supplier has the data, and without a reference number the container is not released

The EU Deforestation Regulation (EUDR) applies from December 30, 2026 to large and medium-sized companies, and from June 30, 2027 to micro and small ones. After two postponements, the European Commission confirmed in May 2026 that it is not proposing a third.

The legal duty sits with the company that first places the goods on the EU market, usually the importer. But that company cannot meet it without data that only the supply chain in Asia holds.

Three things to get right:

The data is about the plot of land, not the factory. Every shipment needs the coordinates of the land where the wood, rubber or other commodity was grown, even if it was grown in a different country from where the product was made.
The product list changed on September 18, 2026. Leather, retreaded tires and several rubber articles came out. Wooden furniture, plywood, paper, new tires and rubber gloves are still in.
Customs enforces it at the border. From December 30, an EU customs declaration for a listed product is rejected unless it carries a due diligence statement reference number or a valid exemption code.

From plot to EU customs: four handovers

① Supplier in Asia

Collects plot coordinates, harvest dates and legality documents for every input

When: before the goods ship
② EU importer

Checks the data, assesses risk and files a due diligence statement in the EU Information System

Receives: a reference number
③ EU customs

The reference number goes on the customs declaration under code C716

If missing: declaration rejected
④ National authority

Checks 1%, 3% or 9% of operators a year, depending on country risk

Records: kept for five years

Is EUDR really starting on December 30, 2026?

Yes, on everything published so far. The dates are fixed in law, the IT system is live and the customs codes are issued.

Table 1. EUDR timeline
Date	Milestone
June 29, 2023	Regulation (EU) 2023/1115 enters into force
December 2024	First one-year postponement
December 23, 2025	Regulation (EU) 2025/2650 published: second postponement, simpler duties for companies further down the chain
May 4, 2026	Commission review confirms no further postponement
Late June 2026	The EUDR Information System reopens for registrations and statements
July 13, 2026	Commission adopts new rules on product scope and on the Information System
September 18, 2026	Delegated Regulation (EU) 2026/2102 on product scope enters into force
September 23, 2026	Revised customs document codes published
December 30, 2026	Applies to large and medium operators and traders, and to small timber companies already under the EU Timber Regulation
June 30, 2027	Applies to other micro and small companies
December 30, 2027	Applies to newly added products such as soluble coffee

Source: European Commission: EUDR; European Commission, Jul 13, 2026; iCustoms timeline; Hogan Lovells

As of late October, no proposal to change these dates was on the table.

Which products shipped from Asia are covered?

EUDR covers seven commodities and a list of products made from them. This is the list as it stands after the 2025 and 2026 changes.

Table 2. EUDR product scope after the 2025 and 2026 amendments
Commodity	Still covered (HS codes)	Removed
Wood	Chapter 44 (logs, sawn wood, plywood, panels, pellets, pallets sold as goods); pulp (47); paper and paperboard (48); wooden seats (9401); wooden furniture (9403); prefabricated wooden buildings (9406 10)	Printed products in Chapter 49 (December 2025); aircraft and vehicle seats (2026). Bamboo and rattan are confirmed not to be wood
Rubber	Natural rubber (4001); compounded and unvulcanized forms (4005–4008); new tires (4011); inner tubes (4013); gloves and apparel (4015); hard rubber (4017)	Conveyor and transmission belts (4010); other vulcanized articles (4016); retreaded and used tires
Palm oil	Palm oil and palm kernel oil (1511, 1513); kernels (1207 10); oilcake (2306 60); some derivatives	More derivatives are added from December 30, 2027
Coffee	Coffee beans, roasted or not (0901)	Soluble coffee is added from December 30, 2027
Cocoa	Beans, paste, butter, powder and chocolate (1801–1806)	—
Soya	Beans (1201 90), flour (1208 10), oil (1507), oilcake (2304)	Soya beans for sowing
Cattle	Live cattle and beef	Hides, skins and leather

Source: iCustoms: commodities; Coolset; QIMA, Oct 8, 2026

Most entries carry an "ex" in the legal text, which means only goods that actually contain the commodity are covered. For rubber, that is natural rubber from the *Hevea* tree; synthetic rubber is out.

What does the EU importer need from an Asian supplier?

The regulation lists the information in Article 9. In practice the importer will send it to you as a questionnaire.

Table 3. Information the EU importer needs from the supply chain
Data	What exactly	Who usually holds it
Product description	Trade name and type. For wood: the common name and full scientific name of each species	Manufacturer
Quantity	Net mass in kilograms, or volume or number of items	Manufacturer
Country of production	The country where the commodity was grown or harvested	Raw-material supplier
Geolocation of every plot	Latitude and longitude to at least six decimal places. Plots over four hectares need a polygon that traces the boundary; smaller plots need one point	Forest owner, plantation or farmer
Date or time range of production	When the commodity was harvested	Raw-material supplier
Supply chain contacts	Name, address and email of each supplier	Each tier
Proof of no deforestation	Evidence that the land was not deforested after December 31, 2020	Raw-material supplier, often with satellite checks by the importer
Proof of legality	Land-use rights, harvest permits and other documents required by the country of production	Raw-material supplier

Source: Regulation (EU) 2023/1115, consolidated; TraceX: Article 9

Low risk does not mean no data

The Commission sorts countries into three tiers. The tier that matters is the one for the country where the commodity was grown.

Table 4. Country risk tiers
Tier	Countries	What changes	Share of operators checked each year
Low	About 140, including China, Japan and the United States	Simplified due diligence: no formal risk assessment or mitigation unless there is a specific concern	1%
Standard	About 50, including Indonesia, Malaysia and Brazil	Full due diligence	3%
High	Belarus, Myanmar, North Korea, Russia	Full due diligence and the most checks	9%

Source: Linklaters; iCustoms timeline

Even for a low-risk country, the importer still has to collect the information, including geolocation, and file a statement. The country list adopted in May 2025 was still the one in force in late October 2026.

Who files what?

The 2025 amendment took the paperwork off companies further down the chain. The first importer still carries the full load.

Table 5. Who files what under EUDR
Role	Who it is	Duty
Operator	Whoever first places the product on the EU market, usually the importer. If a non-EU company sells directly into the EU, the first EU company that makes the goods available is treated as the operator	Carry out due diligence and file a due diligence statement (DDS) in the EU Information System. The system returns a reference number
Downstream operator	A company that makes or sells products from goods already covered by a DDS	No new DDS. The first one in the chain collects and keeps the reference numbers
Trader	A company that sells the goods on	Keep supplier and customer records for five years
Micro or small primary producer	Small growers placing their own produce on the market	A one-off simplified declaration
Supplier outside the EU	Manufacturer or exporter in Asia	No direct legal duty under EUDR. The duty to supply data comes from your contract with the buyer

Source: Ploum on Regulation (EU) 2025/2650; Regulation (EU) 2023/1115, consolidated

What happens at EU customs?

The statement reference number has to appear on the customs declaration. The Commission issued revised document codes on September 23, 2026.

Table 6. EUDR customs document codes
Code	Meaning
C716	Reference number of a due diligence statement. The standard code for imports
C717	Identifier of a simplified declaration by a micro or small primary producer
Y129	Goods under a listed heading that fall outside the scope, such as rubber goods with no natural rubber
Y132	Products produced before June 29, 2023
Y133	Used or second-hand goods and waste
Y187	Samples of negligible value
Y190	Packaging used only to carry another product

Source: iCustoms: TARIC document codes; Finnish Customs; DHL Global Forwarding

How it works in practice:

The code and number go in the documents section of the declaration. Every listed tariff code carries a condition, so a declaration with no statement, simplified declaration or valid exemption code is rejected.
Goods can move under transit, customs warehousing or inward processing without a statement. The number is needed when they are released for free circulation.
"Y" codes are claims. Customs or the national authority can ask for the evidence behind them.
Forwarders and customs brokers need the number before the vessel arrives. They pass it on; they do not check that it is valid.

Where does it get hard in China, Taiwan and Southeast Asia?

Table 7. Common problems in Asian supply chains
Situation	The problem	What helps
Made in China	China is low risk, but buyers still need plot coordinates. Chinese rules on mapping data, data security and personal information make suppliers cautious about sending coordinates abroad. A German timber association reported in 2024 that China had declined to share geolocation data on security grounds. A PwC review in late 2025 found no outright ban and said approval routes exist	Agree early on what is being shared, in what format and through which channel. Suppliers should check local data-export requirements
Mixed raw materials	Factories blend wood or rubber from several sources and keep paper records	Segregate batches, or declare every plot that could be in the batch
Imported inputs	Chinese and Taiwanese processors import logs, pulp and natural rubber. The plot data sits two or three tiers upstream	Add a data clause to raw-material purchase contracts now
Smallholder rubber	About six million smallholders grow roughly 85% of the world's natural rubber. Michelin alone has mapped around two million plots	Buy from processors that already run traceability programs
Indonesia and Malaysia	Standard-risk tier, so full risk assessment applies	Expect more questions and more documents

Source: Mongabay, Aug 2024; PwC, Dec 2025; LiveEO; Mongabay, May 2026

The stakes are large on the wood side: China supplies nearly half of the EU's timber furniture and more than 40% of its paper boxes, according to figures from the campaign group Mighty Earth.

What happens if the data is missing or wrong?

Table 8. Consequences of missing or wrong data
Consequence	Detail
At the border	Customs declaration rejected; goods not released for free circulation
Fines	The maximum must be at least 4% of the operator's annual EU-wide turnover
Goods and revenue	Can be confiscated
Public contracts	Temporary exclusion from public procurement and funding
Checks	1%, 3% or 9% of operators each year, depending on country risk
Records	Kept for five years

Source: Regulation (EU) 2023/1115, consolidated; HQTS, Nov 6, 2026

The penalties fall on the EU company. The commercial consequence falls on the supplier: an importer that cannot file a statement cannot buy. Inspection firm HQTS notes that supplier data is often available but not verifiable, and that a coordinate alone does not prove compliance.

A 7-step checklist for suppliers before December 30

Check your products against the current list
- Match each product's HS code to the table above.
- Note what dropped out in September 2026, so you do not collect data you no longer need.
Trace each input to its country of harvest
- Ask every raw-material supplier where the wood, pulp or rubber was grown.
- Record the country, region and supplier for each batch.
Collect plot coordinates in the buyer's format
- Six decimal places; polygons for plots over four hectares.
- Ask the buyer which file format their system accepts.
Gather legality documents
- Land titles or concession rights, harvest permits, and any export permits.
- Translate summaries where the buyer needs them.
Deal with mixed batches
- Segregate EU-bound production where you can.
- Where you cannot, list every plot that may be in the batch.
Agree how the data will be transferred
- Decide the channel, the format and who holds the files.
- In China, confirm whether sending coordinates abroad needs approval.
Put the reference number into your shipping process
- Ask the buyer for the statement reference number before the cargo sails.
- Add it to the shipping instruction so the forwarder and the EU customs broker have it.

Frequently asked questions

When does EUDR start?

December 30, 2026 for large and medium-sized operators and traders, and for small timber companies already covered by the EU Timber Regulation. Other micro and small companies follow on June 30, 2027.

Will EUDR be delayed again?

Nothing indicates it. The Commission's review of May 4, 2026 proposed no postponement, the Information System reopened in June, and the product list and customs codes were finalized in September.

Is wooden furniture covered by EUDR?

Yes. Wooden furniture under HS 9403 and wooden seats under 9401 are covered, along with plywood, panels, pulp and paper. Seats for aircraft and motor vehicles were removed in 2026, and bamboo and rattan are not treated as wood.

Are suppliers outside the EU legally bound by EUDR?

Not directly. The legal duty is on the company that first places the goods on the EU market. Suppliers are bound through their contracts, because the importer cannot file a statement without their data.

What geolocation data is required?

The latitude and longitude of every plot where the commodity was produced, to at least six decimal places. Plots larger than four hectares need a polygon; smaller plots need a single point. The date or period of harvest is also required.

China is classified as low risk. Do Chinese suppliers still need to provide plot data?

Yes. Low-risk status removes the formal risk assessment, not the information duty. The importer still has to collect geolocation and file a statement.

My product is made in Taiwan or China from imported wood or rubber. Which country counts?

The country where the trees or rubber were grown. That country sets the risk tier, and the plot data must come from there.

What is a DDS reference number, and where does it go?

It is the number the EU Information System issues when the importer files a due diligence statement. It goes on the EU customs declaration under document code C716, and the forwarder needs it before arrival.

Are the pallets and cartons used for shipping covered?

No, if they only support, protect or carry another product. Pallets or cartons sold as goods in their own right are covered. The customs exemption code for carrying packaging is Y190.

What are the penalties?

Member states must set fines whose maximum is at least 4% of the operator's annual EU-wide turnover. Goods and revenue can be confiscated, and the company can be excluded from public contracts for a time.

About this guide

Paul Liang
Mingsung International Logistics, Taipei

Last reviewed: Nov 12, 2026
Experience: Written by Paul Liang at Mingsung International Logistics in Taipei. Mingsung ships FCL and LCL ocean freight from Taiwan and mainland China, and handles the booking and shipping-instruction data that destination customs brokers rely on.
Coverage: Covers EUDR application dates, product scope after the 2025 and 2026 amendments, supplier data requirements, roles in the supply chain, EU customs codes and the practical problems in Asian supply chains.
Based on: Based on Regulation (EU) 2023/1115 as amended by Regulations (EU) 2025/2650 and (EU) 2026/2102; the European Commission's EUDR pages and its announcement of July 13, 2026; the EUDR customs document code list as revised on September 23, 2026; and analysis by Hogan Lovells, Linklaters, QIMA and others.
Please note: General information, not legal advice. Product scope turns on the exact tariff code and the "ex" conditions in Annex I; check the consolidated text and ask your EU buyer or a qualified adviser. Mingsung does not prepare due diligence statements and does not verify geolocation or legality data.

Update log

Nov 12, 2026First published. Reflects Delegated Regulation (EU) 2026/2102 and the customs code list of September 23, 2026.
Jan 11, 2027Scheduled review after the first application date.

EUDR Starts Dec 30, 2026: What Asian Suppliers Must Provide

Bottom line

From plot to EU customs: four handovers

Is EUDR really starting on December 30, 2026?

Which products shipped from Asia are covered?