EUDR Compliance for Natural Products: What B2B Importers Must Know in 2026

Key takeaways

• The EU Deforestation Regulation (EUDR — Regulation (EU) 2023/1115) prohibits placing on the EU market or exporting from it any in-scope commodity unless it is (a) deforestation-free (no land conversion after 31 December 2020), (b) produced in compliance with the country-of-production legislation, and (c) covered by a valid Due Diligence Statement (DDS) with geolocation data.
• In-scope commodities are cattle, cocoa, coffee, oil palm, rubber, soya, and wood — plus their listed derivatives. Many natural-product B2B buyers think this excludes herbs and dried fruit. It does for the named seven only — but adjacent products and shared logistics flows are still affected, and the Commission has signalled that scope expansion is on the policy agenda.
• Operators (first placers on the EU market) carry full due diligence liability; downstream traders carry a lighter regime. Penalties include fines of at least 4% of EU annual turnover, confiscation, and exclusion from public procurement.
• The applicable date is 30 December 2025 for large operators and traders and 30 June 2026 for SMEs — confirmed after a one-year postponement adopted in late 2024. Plan now; the GIS, DDS, and supplier-data infrastructure cannot be built in 30 days.

Introduction

The EU Deforestation Regulation is the most consequential supply-chain compliance shift since REACH. It does not stop at palm oil and timber. Its data infrastructure — geolocation per parcel of land, supplier due diligence, DDS reference numbers travelling the supply chain in the EU TRACES NT environment — sets the operational template for the next wave of EU sustainability law (CSRD Scope 3, CBAM, DPP, Forced Labour Regulation).

This guide explains what EUDR requires, who is liable, what scope means in practice for natural-product procurement, what to demand from your suppliers, and how to structure your data architecture so the regulation becomes a competitive advantage rather than a brake on growth.

What EUDR actually requires

Three substantive obligations apply to every in-scope shipment placed on or exported from the EU market:

1. Deforestation-free: the relevant commodity (and any product made from it) must be produced on land that has not been subject to deforestation or forest degradation after 31 December 2020.
2. Legality: production must comply with the relevant legislation of the country of production — including land-use rights, environmental protection, forest-related rules, third-party rights, labour rights, human rights protected under international law, the principle of free, prior and informed consent (FPIC), and tax, anti-corruption, trade and customs regulations.
3. Due Diligence Statement (DDS): a statement filed in the EU information system (TRACES NT) before the goods are placed on or exported from the EU market, containing the geolocation coordinates of every plot of land where the commodity was produced and a risk assessment.

The DDS reference number then accompanies the shipment downstream. Subsequent operators rely on it; downstream traders pass it on.

In-scope commodities and derivatives

The seven commodities in Annex I of the regulation:

| Commodity | Notable derivatives in scope | | --- | --- | | Cattle | Bovine leather, beef, offal, hides | | Cocoa | Cocoa beans, butter, paste, powder, chocolate | | Coffee | Green and roasted coffee, coffee extracts | | Oil palm | Palm oil, palm kernel oil, palm derivatives, glycerol from palm, oleochemicals | | Rubber | Natural rubber, tyres, rubber-derived industrial goods | | Soya | Soybeans, soya oil, soya cake, soya derivatives | | Wood | Sawn wood, pulp, paper, charcoal, furniture |

Derivatives are listed by HS code in the Annex. A single palm-oil derivative used as a carrier in a cosmetic, an emulsifier in a snack, or a base in an essential-oil dilution can pull an otherwise non-EUDR product into scope.

Why it affects natural-product supply chains

Herbs, dried fruit, essential oils, and most botanical extracts are not on the Annex I list. But the regulation reaches natural-product B2B procurement through five routes:

1. Palm-oil-derived ingredients

Many cosmetic-grade emulsifiers, surfactants, glycerin sources, and natural-derived actives originate from palm-oil chemistry. A natural-extract ingredient using palm-derived glycerin as its solvent or carrier brings the palm-oil EUDR obligation along with it.

2. Soy lecithin and soy-derived emulsifiers

Standard in many private-label snack and confectionery formulations. Triggers EUDR for the soy component.

3. Cocoa-containing finished products

Private-label snack lines that include cocoa, chocolate coatings, or cocoa-butter components are squarely in scope.

4. Coffee in beverage and HORECA categories

Coffee-bean and coffee-extract sourcing is in scope; downstream products (RTD coffee, coffee-flavoured snacks) are derivative-in-scope.

5. Logistics and packaging wood

Wooden pallets and wood-derived packaging are in scope. Many EU importers now require EUDR-compliant pallet declarations from Turkish (and all other) suppliers as a procurement pre-condition.

For a comprehensive view of how EUDR fits into the broader sustainable agriculture and ESG landscape, see our dedicated guide.

Who is the "operator" and who is the "trader"?

The regulation distinguishes:

• Operator — the natural or legal person that, in the course of a commercial activity, places the relevant products on the EU market for the first time, or exports them. This is most commonly the EU importer, but for a Turkish supplier shipping under DDP or acting as importer of record, the supplier becomes the operator.
• Trader — any person in the supply chain other than the operator who, in the course of commercial activity, makes the products available on the EU market. Smaller compliance burden than operators; SME traders carry lighter still obligations.

Operators bear the full due diligence obligation: data collection, risk assessment, risk mitigation, DDS submission. Traders must collect and keep the DDS reference and supplier identity data and provide it on request.

What a Due Diligence Statement contains

The DDS is filed via the EU TRACES NT information system. Its core data:

1. Operator identity — name, address, EORI number.
2. Commodity / product description — HS code, trade description, scientific name where applicable (genus and species), quantity (mass, volume, units), supplier identity.
3. Country of production — and, where applicable, parts of countries.
4. Geolocation — geographic coordinates (latitude and longitude) of every plot of land where the relevant commodity was produced. For plots ≥ 4 hectares, polygon coordinates are required; for smaller plots, point coordinates suffice. For cattle, all establishments where the cattle were kept.
5. Risk assessment — methodology, conclusion, mitigation measures.
6. Conclusion — explicit declaration that the operator has performed due diligence and has found no or only negligible risk of non-compliance.

The DDS reference number returned by TRACES NT must accompany the customs declaration for the shipment.

Country benchmarking: low / standard / high risk

The Commission publishes a country benchmarking classifying countries (or parts of countries) as low, standard, or high risk of producing relevant commodities not in compliance with EUDR. The methodology considers deforestation rate, agricultural expansion, production trends, and rule-of-law indicators.

Practical effect:

• Low-risk countries — operators may rely on a simplified due diligence (collection of information without the full risk assessment and mitigation steps). DDS still required.
• Standard-risk — full due diligence.
• High-risk — full due diligence + enhanced scrutiny, 9% of operators and shipments subject to compliance checks (vs 3% standard, 1% low).

The benchmarking is dynamic. Confirm the current country tier at the time of every quarterly DDS planning cycle.

Geolocation data: what suppliers must provide

The single biggest practical change for buyers and suppliers. Required:

• Latitude and longitude of every production plot, in decimal degrees, WGS84 reference system.
• Polygon vertices for plots of 4 hectares or more (recommended for all plots).
• Date or time range of production linked to each plot.
• Plot identification consistent with national land registries where possible.

Most natural-product Turkish suppliers source from cooperative networks of small farms — often hundreds or thousands of plots per harvest. The data architecture must aggregate plot-level geolocation, link it to the lot identifier on the buyer's PO, and feed the DDS template. Suppliers that have invested in a digital traceability platform are ahead; those that have not will scramble.

Supplier qualification questionnaire

A serious EUDR supplier qualification questionnaire — to be sent to every Turkish, Asian, and African supplier of in-scope or adjacent product — covers:

1. Scope mapping — which of the supplier's SKUs to your account are in EUDR scope, which are derivative-in-scope, which are out of scope.
2. Geolocation capability — can the supplier provide plot-level coordinates per lot? In what format? With what accuracy?
3. Plot polygon data — for parcels ≥ 4 ha, can the supplier provide WGS84 polygon coordinates?
4. Production date traceability — link from plot to harvest to processing lot to outgoing lot.
5. Legal compliance evidence — land-use right documentation, environmental permits, labour-law compliance, indigenous-rights compliance where relevant.
6. Country tier monitoring — how does the supplier track changes in country benchmarking?
7. DDS data delivery format — XML, CSV, API, or manual?
8. Penalty allocation — contractual allocation of regulatory fines if supplier-side data is non-compliant.

For private-label projects where the EU brand is the operator, the supplier-data quality directly determines the brand's regulatory exposure. The private-label snacks production guide covers how to integrate this into the production timeline.

Penalties and enforcement

EUDR penalties are designed to be deterrent:

• Fines of at least 4% of the operator's annual EU turnover for the most serious infringements.
• Confiscation of the relevant products and any revenues obtained from non-compliant transactions.
• Temporary exclusion from public procurement and access to public funding.
• Temporary prohibition from placing relevant products on the EU market.

Member states implement the penalty regime nationally; expect heterogeneous enforcement intensity in the first 18 months, converging upward as case law develops.

Two short scenarios

Scenario 1 — Cosmetic brand reformulating a body lotion. The brand discovers its glycerin supplier sources from palm-derived feedstock. The brand is the EU operator and now bears full DDS obligation for the palm-oil component. Resolution: switch to certified RSPO-segregated palm glycerin with full geolocation data, or substitute to non-palm-derived glycerin (e.g., rapeseed-derived or geothermal fermentation-derived). The reformulation adds 4 weeks; the alternative is a structural compliance liability.

Scenario 2 — Snack brand with chocolate-coated dried fruit. Cocoa is in scope. The brand requires the Turkish co-manufacturer to source cocoa from an EUDR-compliant trader providing geolocation and DDS reference numbers per shipment. The dried fruit itself is out of scope (apricot, fig). The pallet-wood used for export is in scope; supplier provides ISPM-15 + EUDR-compliant pallet declaration.

How Turkish suppliers are responding

Turkish exporters supplying EU retail are investing in:

• Digital traceability platforms linking farm → cooperative → processing facility → export lot.
• GIS infrastructure to record plot polygons during the harvest data-capture cycle.
• Cocoa, coffee, palm-derivative substitution for buyers who want to step out of EUDR scope entirely.
• Pallet declarations standardised in supplier dispatch documents.

For the Arovela product range, the dominant categories — dried fruit, herbs, essential oils — are not on the in-scope Annex I list. Where buyer-formulated products incorporate in-scope derivatives (palm-derived emulsifiers, soy lecithin, cocoa coatings), the supply infrastructure exists to source EUDR-compliant alternatives.

Future scope expansion

The Commission has signalled that EUDR scope is expected to broaden in subsequent revisions. Categories under active discussion:

• Other forest-risk crops — maize, sugarcane, possibly select tree-nut categories.
• Other ecosystems — savannah and grassland conversion (currently only forest).
• Financial-services scope — banks and insurers' indirect exposure.

A buyer who builds the plot-level geolocation, DDS, and supplier-data architecture now is positioned to absorb the next regulatory step at low marginal cost. A buyer who waits is acquiring a structural liability.

FAQ

Are dried apricot, fig, and herbs in EUDR scope? No, not on the Annex I list. But check derivative ingredients used in any formulated product (palm, soy, cocoa derivatives) and the wood pallets used for export — these can pull a shipment into scope.

What is the difference between simplified and full due diligence? Simplified applies to product sourced exclusively from low-risk countries: the operator collects information but is not required to perform the full risk-assessment and risk-mitigation steps. Standard and high-risk countries require full due diligence.

Who pays for the geolocation data? Industry practice is converging on the supplier providing geolocation as part of the lot documentation, with the cost embedded in the unit price. Some buyers fund supplier-side GIS upgrades for strategic categories.

What is TRACES NT? The EU's online platform for sanitary, phytosanitary, and now EUDR documentation. Operators must register, submit DDS filings, and receive reference numbers via TRACES NT. The platform is operated by the European Commission DG SANTE (with DG ENV for EUDR).

Can a non-EU supplier file a DDS directly? Only if acting as the operator (e.g., as exporter of record under DDP). The first EU operator typically files. Suppliers provide the underlying data.

Build EUDR-ready supply now

The regulation is in force. The data infrastructure takes 6–12 months to build, not 30 days. Browse our wholesale and B2B options, see the related supplier migration playbook and sustainable agriculture guide, or request a quote with full traceability documentation.