If you sell furniture, chocolate, tyres, paper or even cosmetics, it's easy to assume that the EUDR is something that only affects other companies—large timber businesses, multinational cocoa producers or organisations working thousands of miles away in tropical forests.

The reality is very different. The EUDR doesn't look at the size of your company. It looks at what's inside your product.

That's where many SMEs get caught off guard. They discover they fall within the scope of the regulation when it's already too late to prepare without unnecessary pressure. In this article, we'll show you—using verified information—how to determine whether your product is covered by the EUDR before an inspection tells you.

What Is the EUDR? In One Sentence

The EUDR (EU Regulation 2023/1115, as amended by EU Regulation 2025/2650) requires businesses to prove that certain products do not originate from land that has been deforested after 31 December 2020.

It doesn't ban the sale of coffee, timber or leather. It requires businesses to demonstrate where the raw material comes from and prove that the land used to produce it was not subject to deforestation.

But the question that really matters isn't simply: Is my product covered?

The Seven Commodities Covered by the EUDR

The regulation covers seven key commodities. If your product contains, or has been manufactured using, any of them, keep reading:

• Timber — from sawn wood to paper, furniture and musical instruments.
• Cocoa — including chocolate, cocoa powder and cocoa butter.
• Coffee — green beans, roasted coffee and instant coffee (subject to confirmation).
• Soy — including oil, flour and animal feed.
• Rubber — tyres, gloves, footwear and inner tubes.
• Oil palm — palm oil used in food, cosmetics and detergents.
• Cattle — beef, leather and gelatine.

If your business deals with even one of these seven commodities, the next step is to find out whether your specific product is included under the regulation.

Processed Products Are Covered Too

This is where many businesses get caught out. The EUDR doesn't only regulate raw commodities. It also covers an extensive list of derived products, set out in Annex I of the regulation.

That means your business may fall under the EUDR even if you never purchase timber, cocoa or rubber directly. Simply using one of these commodities as an ingredient or component in the products you sell may be enough.

Here are a few examples that often surprise businesses:

• A furniture retailer, even if it doesn't manufacture products from raw timber.
• A cosmetics brand using palm oil in its formulations.
• A footwear manufacturer producing shoes with rubber soles.
• A snack or confectionery company selling products containing chocolate or coffee.
• A distributor of tyres or latex gloves.

The principle is straightforward: if your product contains, or has been made using, one of the seven commodities covered by the regulation, it may fall within the scope of the EUDR—even if your business has no direct connection to forests or forestry.

How to Check Whether Your Product Is Covered

Here's how to find out:

1. Identify your product's commodity code (HS Code or TARIC code). This is the same customs classification you use for imports and exports.
2. Compare it with Annex I of the regulation. Annex I lists every commodity and derived product covered by the EUDR, organised by customs code.
3. Check whether your product contains, or has been manufactured using, one of the seven regulated commodities, even if it represents only a minor component.
4. Consider the recycled material exemption. Products made entirely from recycled material are generally excluded. However, if a product combines recycled and virgin material, the virgin portion remains subject to the regulation.

Whether you're a small business or you've never considered deforestation to be relevant to your operations, one fact remains the same: if your customs code appears in Annex I, your product must comply with the EUDR.

Who Needs to Comply? Operator, Trader or Downstream Operator

The EUDR defines different roles, and the obligations vary depending on which one applies to your business.

• Operator – You place a relevant product on the EU market for the first time or export it from the EU. As an operator, you are responsible for carrying out the full due diligence process.
• Trader – You make products that are already on the EU market available to other businesses. Your obligations are more limited and focus mainly on traceability and record-keeping.
• Downstream operator – You manufacture products using materials that are already covered by a Due Diligence Statement (DDS). In this case, you only need to obtain the reference number from your supplier and keep it on record rather than repeating the entire due diligence process from scratch.

Understanding which role applies to your business is just as important as knowing whether your product is covered by the EUDR, because it determines exactly what you are required to do.

Key Dates You Need to Know

The EUDR implementation timeline has changed more than once, so it's important to keep the current deadlines in mind:

• 30 December 2026 – Operators and medium-sized and large companies.
• 30 June 2027 – Micro and small enterprises, with one important exception: if your business was already covered by the former EU Timber Regulation (EUTR), your compliance deadline remains 30 December 2026.

These are the current dates following EU Regulation 2025/2650, published on 23 December 2025. Before this amendment, the regulation was due to apply from December 2025.

As the implementation date has already been postponed several times, our recommendation isn't to relax because "there's still plenty of time." Instead, use that time to prepare properly and avoid a last-minute compliance rush.

If Your Product Is Covered, Due Diligence Comes Next

Confirming that your product falls within the scope of the EUDR is only the first step.

The next step is to establish a due diligence system, including traceability back to the plot of land where the commodity originated, a risk assessment, and the submission of the corresponding Due Diligence Statement (DDS).

At Deslioo, we help SMEs do exactly that: determine whether the regulation applies to their products and implement a practical compliance process—without turning it into a year-long project.

Don't Wait Until an Inspection Tells You

Checking whether your product is covered by the EUDR takes less than an afternoon.

Finding out too late can be much more expensive. The regulation requires national authorities to inspect a minimum percentage of operators every year, with inspection rates increasing according to the level of risk associated with the country of origin.

The longer you wait to verify your products and obligations, the greater your exposure becomes.

If you're unsure about your customs code or your role within the supply chain, it's far better to clarify those questions now than when you're facing an inspection.