From the end of 2025, the new EU regulation to combat global deforestation – officially the EU Deforestation Regulation (Regulation (EU) 2023/1115), or EUDR for short – will come into force. This entails new obligations for many online retailers – particularly in the area of customs clearance and the supply chain. Even if you in Switzerland, the following applies you products in the EU or export them from the EU, you are you affected. MS Direct provides you with practical support for preparation and implementation.
What is the EU Deforestation Regulation (EUDR)?
The EU Deforestation Regulation (Regulation (EU) 2023/1115, or EUDR for short) aims to ensure that products containing certain raw materials do not contribute to deforestation or forest degradation. Companies must therefore prove along their supply chain that the products concerned have been produced legally and without deforestation.
This means:
- Information obligations (e.g. origin, geo-coordinates of cultivation areas, HS codes)
- Risk assessment and risk minimisation where applicable
- Submission of a due diligence declaration via the EU information system
The regulation differentiates between small and medium-sized enterprises (SMEs) and non-SMEs.
Company size & start of application
- Non-SMEs: December 30, 2025
- SMEs: June 30, 2026
Which products are affected by the Deforestation Regulation?
The EUDR concerns seven raw materials and products consisting of, fed with or containing them:
- Cattle (incl. meat, hides, leather)
- Cocoa
- Coffee
- Palm oil
- Rubber
- Soy
- Wood
This also applies to many processed products, for example:
- Paper, cardboard, books, printed matter
- Furniture and components made of wood
- Rubber products
- Foods with palm oil or soy
Products made exclusively from recycled materials are not affected.
Who is affected by the EUDR?
All companies that
- Importing goods into the EU
- export from the EU
- act as importers or exporters in the context of customs declarations.
Important! Regardless of where your company is based – even if you are based in Switzerland, for example – the rules apply as soon as you make products available in the EU or export them from there.
What do you have to do specifically?
The requirements differ depending on the role and size of the company:
Market participants (non-SMEs)
- Establishment and maintenance of a due diligence system consisting of information collection, risk assessment, risk mitigation
- Submission of a declaration of due diligence
Market participants (SMEs)
- Also fundamental duty of care and submission of a declaration of care
- Exception: If upstream companies have submitted a due diligence statement (DDS), it is sufficient to present the reference number if required
Retailers (non-SMEs)
- Treated like a market participant
- Must ensure that the upstream duty of care has been fulfilled
- Must make its own due diligence declaration based on upstream DDSs
Retailers (SMEs)
- No obligation to carry out own due diligence obligations
- No submission of a due diligence declaration
- Duty to provide information: collect identity of suppliers, addresses, etc. and keep for 5 years (keyword: traceability)
What are the exceptions to the Deforestation Regulation?
- SME transition period: Small and medium-sized enterprises are not obliged to submit a DDS until June 30, 2026. After that, the obligations apply without restriction.
- Recycled goods: These are not considered to be newly placed on the market if they consist of materials whose life cycle has already been completed. There are special customs declaration exemptions for such products. If all of a company’s articles fulfil these criteria, the code Y133 can be used. This declares that the recycling exemption applies and no DDS reference number is required.
Important! Even if certain SMEs or traders are subject to less far-reaching due diligence obligations or exceptions apply: The required information must still be provided in full for the customs declaration from December 30, 2025.
New requirement for customs clearance
To ensure that goods can continue to be cleared through customs without any problems, additional information is required from the start of application:
- Exact customs coding at item level (incl. Y & C codes)
- Due Diligence Statement (DDS) Reference number: an electronic declaration that the goods are deforestation-free
The effects on the customs flow are independent of the general audit and reporting obligations under the EUDR. This means that only the additional information required, such as coding and DDS reference number, is relevant for customs clearance. The audit and reporting obligations under EUDR are separate and do not affect the customs process.
What are Y and C codes?
The Y and C codes are document codes in the customs declaration:
- Y codes = declarations or special cases. For example, Y141: Declaration that a company makes use of the SME exemption (until June 30, 2026) or Y133: Declaration that goods are made exclusively from recycled materials.
- C-codes = verification numbers. For example, indication of the DDS reference number that confirms that a product is deforestation-free.
Why you should act now
The implementation of the EUDR is complex – especially for online retailers with global supply chains. You should analyze at an early stage whether and to what extent you are affected and talk to suppliers.
The most important questions for you as an online retailer at the start
- Are my products affected?
Check whether you are offering raw materials or affected products. - What is my role under the EUDR?
Are you a market participant or a trader? - How is my company classified?
As an SME or non-SME? - What obligations does this entail?
What due diligence and documentation requirements do I have to fulfill? - Do I have all the necessary information from my suppliers?
To fulfill your EUDR obligations, you need complete information – ideally including DDS reference numbers. - How do I document the required data?
Use suitable tools or processes to securely manage due diligence declarations or their references.
Your EUDR checklist in a nutshell
Preparing for the EUDR is complex, but feasible. The following steps are recommended:
- Check products: Which goods contain affected raw materials?
- Involve suppliers: Is geo-data, DDS information and evidence available?
- Adapt systems: Are ERP and customs software prepared for Y and C codes and DDS?
- Test data transmission: Do API or CSV interfaces work for customs declarations?
Further information
Information page of the Federal Ministry of Agriculture and Food (BLE) in Germany
Information from the BLE on the impact of the regulation on customs declarations
This article has been researched and compiled with great care. Nevertheless, we assume no liability for the accuracy, completeness or timeliness of the content.