Fundamental obligations

Deferral until December 30, 2026 for large and medium-sized companies:

• Prohibition to introduce, commercialize or export products that are not free of deforestation.
• Obligation to exercise due diligence and file returns in the reporting system
• Control procedures by the competent authorities with risk-based approach
• Regime of corrective measures and penalties in case of noncompliance

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Deferral until June 30, 2027 for micro and small companies:

• Additional six-month extension for operators that are individuals, microenterprises or small companies. Exception: wood products, whose start date is December 30, 2026 for all company sizes.

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Legality requirements

For a product to be considered legal under these regulations, it must meet two conditions:

• Cut-off date (December 31, 2020). The raw materials must have been produced on land that has not been deforested after this date.
• Forest degradation (specific for wood). Wood products must have been obtained without causing forest degradation after December 31, 2020. Degradation includes, for example, converting primary forest to plantation forest.
• Operators must collect the geolocation coordinates of all plots of land where the raw material was produced.

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Products concerned (Annex I)

The regulation applies to products containing, having been fed or processed using seven raw materials: cattle, cocoa, coffee, oil palm, rubber, soybeans and wood.

Main non-food products affected:

• Rubber Products: Tires, vulcanized rubber garments, conveyor or transmission belts.
• Wood and Paper Manufactures: Wooden furniture and parts thereof, Prefabricated buildings, Tools, frames and handles, Carpentry works for construction.
• Bovine Cattle Derivatives: Raw hides and skins, tanned, parchment-treated or prepared hides (for footwear, upholstery or leather goods).
• Chemical and Industrial Products (Oil Palm): Industrial fatty acids (stearic, oleic), Industrial fatty alcohols, Glycerol with a minimum purity of 95%.

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New categories of operators

Regulation (EU) 2025/2650 introduces new categories to simplify procedures and reduce the administrative burden:

Micro or small primary operators (MPOPs)

• Individuals, micro or small companies established in countries classified as “low risk” that produce raw materials in the same country.
• They are not required to perform the full due diligence process.
• They file a “simplified single filing declaration”.
• You can replace the exact geolocation coordinates with the postal address of the parcel.

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Downstream operators

• Individuals or legal entities that process, market or export products that have been previously covered by a due diligence declaration.
• Their obligations have been equated to those of “traders”.
• They do not have to exercise due diligence or file new declarations, thus avoiding duplication.
• Subsequent operators that are not SMEs are required to register in the information system.

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Compulsory registration in the Information System

Registration is mandatory:

• Merchants other than SMEs: large and medium-sized commercial enterprises.
• Subsequent operators other than SMEs: those that process or export products with prior declaration.
• Authorized representatives: when an operator delegates its tasks to a third party.

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Registration requirements:

• For companies that import or export, the profile must include their EORI number.
• The obligation to register must be complied with prior to placing on the market, marketing or exporting the products.
• Fully enforceable as of December 30, 2026 for large companies.