The EUDR, the EU deforestation regulation, applies to large and medium companies from 30 December 2026. It covers cattle, cocoa, coffee, oil palm, rubber, soya, wood and Annex I derivatives. The duty sits with the operator placing goods on the EU market, but exporters will be asked for plot location and legality data even though Türkiye is low risk.
When does the EUDR apply?
The dates have moved twice. The table below reflects the consolidated Regulation of 18 September 2026 and the Commission’s page.
| Date | Applies to |
|---|---|
| 30 December 2026 | Large and medium companies, plus micro and small companies for products in the EU Timber Regulation annex |
| 30 June 2027 | Micro and small companies and natural persons established by 31 December 2024 (timber regulation products excepted) |
| 30 December 2027 | Products added to Annex I by Regulation 2026/2102 |
Note that 30 June 2027 is not for every small business. Article 38(3) requires establishment by 31 December 2024.
Which products are covered?
There are seven commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood. What decides coverage is the customs code in Annex I, not the product name.
| Commodity | Examples from Annex I |
|---|---|
| Cattle | Live cattle, beef, edible offal |
| Cocoa | Beans, paste, butter, powder, chocolate and food preparations containing cocoa |
| Coffee | Coffee (0901), and from 30 December 2027 coffee extracts (2101 11 00) |
| Oil palm | Palm oil and derivatives, and from 30 December 2027 certain chemical derivatives and soaps |
| Rubber | Natural rubber, new tyres, certain rubber articles |
| Soya | Beans, flour, oil, oilcake |
| Wood | Sawn timber, plywood, pallets, wooden furniture, pulp and paper headings |
Regulation 2026/2102 changed the list. Leather and raw hides came out of Annex I, used products and packing material used to carry another product were excluded, and soluble coffee was added. Hazelnut, raisin and olive oil headings are not in Annex I. Still check your own CN code, because a preparation containing cocoa may fall under a different heading.
What is Türkiye’s risk classification?
Türkiye is on the low risk list in the annex to Implementing Regulation 2025/1093. For commodities produced in Türkiye, this opens simplified due diligence under Article 13: after assessing supply chain complexity and the risk of mixing, the EU operator does not have to carry out the risk assessment and mitigation steps in Articles 10 and 11.
Low risk is not an exemption. The Commission guidance is clear that these operators still collect the Article 9 information, keep a due diligence system and file a statement.
The real issue is origin. The classification follows the country where the commodity was produced, not the country it ships from. Soya from Brazil or cocoa from Côte d’Ivoire processed in Türkiye stays standard risk, because neither country is on the low risk list. Article 13(3) specifically flags circumvention through processing of this kind.
Is the Turkish exporter directly liable?
In most cases the direct addressee is on the EU side. According to the guidance, the operator for goods produced outside the EU is generally the person shown as importer on the customs declaration. If that importer is not established in the EU, the first EU person making the product available is deemed an operator under Article 7, on top of the obligation of the non-EU operator.
Our inference is this: even where the legal duty sits with the importer, the data has to come from you, so the effect reaches the exporter through contracts and customer requests. The Article 38 date also depends on the size of the operator placing the goods, not on yours. A small exporter selling to a large buyer may need to be ready for 30 December 2026. If you clear goods as importer yourself, have your position reviewed separately.
There is one more route. Under Article 4a, a micro or small primary operator established in a low risk country and placing its own production on the market can file a one-time simplified declaration and use a postal address in place of geolocation. Check each element of the definition.
What should a Turkish exporter prepare?
- Product screening: check every export line by CN code against Annex I, and flag separately the codes added from 30 December 2027.
- Origin mapping: identify the country and, where possible, the plot for each commodity. Separate low and standard risk sources.
- Location data: under Article 2, latitude and longitude need at least six decimal digits. Plots over 4 hectares for commodities other than cattle need polygons. For cattle, location relates to the establishments where the animals were kept.
- Deforestation evidence: prepare verifiable information that the land was not deforested after 31 December 2020.
- Legality documents: show compliance with the laws of the country of production. Article 9 also asks for the arrangement giving the right to use the land.
- Segregation: the guidance says goods mixed with products of unknown origin are not compliant, and mass balance is not enough.
- Records: EU operators keep this information for five years. Align your contracts with that period.
Enforcement on the EU side is not light. Under Article 25, Member States provide for fines with a maximum of at least 4 percent of EU turnover for legal persons, along with confiscation of products and revenue.
This guide is general information, not legal advice. For a compliance roadmap see Green Transition and Sustainability, and for carbon rules read our CBAM guide. If you are planning an investment, include this in your feasibility study.
Frequently asked questions
Has the EUDR been postponed?
Twice, in December 2024 and December 2025. In the current text the date for large and medium companies is 30 December 2026, and 30 June 2027 for micro and small companies established by 31 December 2024, timber regulation products excepted. We saw no further postponement as of 7 November 2026.
Is Türkiye exempt from the EUDR because it is low risk?
No. Low risk can remove risk assessment and mitigation, but information collection, location data, a due diligence system and the statement remain. The classification covers only commodities produced in Türkiye.
Are hazelnut or olive oil exporters covered?
Hazelnut, raisin and olive oil headings are not in Annex I. Still check the CN code. A mix containing cocoa, or wooden pallets sold as products in their own right, can be assessed differently.
Are furniture and wooden packaging covered?
Wooden furniture headings are in Annex I. Pallets and crates sit under heading 4415, but single use packing used to carry another product was excluded by Regulation 2026/2102. Pallets sold as products stay in scope.
What should a chocolate maker in Türkiye do?
Chocolate is in Annex I under heading 1806. What counts is the country where the cocoa was produced. Your buyer will need the source country and plot location from you. If the source is standard risk, a risk assessment is required as well.
Official sources
- Regulation (EU) 2023/1115, konsolide metin, 18.09.2026
- Commission Delegated Regulation (EU) 2026/2102 (Ek I değişikliği), OJ 17.09.2026
- Regulation (EU) 2025/2650 (ikinci EUDR değişikliği)
- Commission Implementing Regulation (EU) 2025/1093 (ülke sınıflandırması)
- Komisyon EUDR kılavuzu, OJ C/2026/3896
- European Commission, EU Deforestation Regulation sayfası
This guide is general information, not legal or financial advice. Programme terms can change, so check the current official text before applying.
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