What the regulation requires
Regulation (EU) 2023/1115, known as the EUDR, covers seven commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood, and many products made from them. To be sold in or exported from the EU, they must be deforestation-free (produced on land not deforested after 31 December 2020), produced legally under the laws of the country of production, and covered by a due diligence statement.
When it applies
After two postponements, the rules apply from 30 December 2026 for large and medium-sized companies, and from 30 June 2027 for most micro and small companies. The Commission published its simplification review in May 2026 together with new guidance, and said it would not reopen the text of the regulation.
Who files, and who supplies the evidence
The legal duty sits with the company that places the product on the EU market, usually the importer. But the importer can only file its statement with information that starts at the farm. In practice, European buyers will pass the requirements to their Brazilian suppliers, and many already do.
Brazil is classed as a standard-risk country in the Commission’s benchmarking. That means importers must carry out full due diligence, including a risk assessment, rather than the simplified version available for low-risk countries.
What buyers will ask for
- Geolocation of every plot where the commodity was produced: a point for small plots, a polygon for plots over four hectares.
- Proof of legality: land rights, environmental registration such as the CAR, licences, and compliance with labour and tax rules.
- Traceability from plot to shipment, with no mixing of verified and unknown origin along the way.
- Information on quantities, dates of production and the supplier chain.
How to get ready
Start with mapping: collect plot coordinates and polygons, and the CAR and licences that go with them. Agree with each European buyer the format in which data will travel, since many use their own platforms. Set up segregation where verified and unverified volumes meet, at cooperatives, warehouses and mills. Then test the whole chain on one shipment before volumes depend on it.
Where Gibson fits
Gibson works between the two sides: helping Brazilian exporters understand exactly what their European buyers will ask for, and helping European companies find suppliers who can provide it. Preparing early turns a compliance burden into a reason to be chosen.