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Implementation

EUDR application dates and preparation timeline

The current application dates depend on the operator, product and transition conditions. Check the relevant legal entry.

Reviewed 4 October 2026 · Independent educational guidance

Current dates at a glance

SituationApplication date
Main application of the specified provisions under Article 38(2)30 December 2026
Qualifying micro or small operators established as such by 31 December 2024, subject to the EUTR-product exception30 June 2027
Specified newly added Annex I products with a deferred date30 December 2027

The June 2027 treatment is conditional. Medium-sized operators do not fall within that micro/small postponement. Products already covered by the EUTR Annex are excluded from that postponement.

Entry into force is different

The regulation entered into force in 2023. That does not mean all substantive obligations applied immediately. Article 38 separates entry into force from application of the specified provisions, and subsequent amendments changed the application schedule.

Older material may still mention December 2024 or December 2025. Use the current consolidated text and the authentic amending acts to resolve the present position. A proposed delay should not be treated as law before its adoption.

Product-specific and timber transitions

Commission Delegated Regulation (EU) 2026/2102 amended Annex I. Certain new entries, including coffee extracts and frozen cattle tongues, expressly apply from December 2027. This does not postpone existing coffee or cattle product coverage as a whole.

Article 37 contains a separate timber transition concerning EUTR timber products produced before 29 June 2023. Establish the production and placement dates before reaching a conclusion about older timber stock.

Prepare around the evidence gaps

A suggested preparation sequence starts with scope and role decisions, then supplier and location records, then assessment and release controls. Test a complete product flow while there is time to resolve missing evidence. Assign responsibility for updates to the legal position.

Do not wait until the final application date to discover that plot records cannot be linked to intake lots. Use the due diligence workflow and geolocation guide to identify the information that your review process needs.

Primary sources

Article 38; Article 37; current Annex I. Legal review used the consolidated text dated 18 September 2026. Consolidated texts are documentation tools; authentic acts are published in the Official Journal.

Check the current sources and relevant competent authority guidance for your situation. This page is not legal advice or a compliance determination.