The EU Deforestation Regulation (EUDR) applies to companies that place certain raw materials and products made from them on the market in the EU, make them available, or export them from the EU. The regulation is particularly relevant to e-commerce because it involves the interplay of international goods flows, customs clearance, and product data. Swiss online retailers may also be affected if they sell such goods to the EU. MS Direct provides you with practical guidance throughout the preparation and implementation process.
The EUDR has been amended several times since it was originally adopted. At the end of 2025, the EU postponed its implementation once again and simplified various obligations along the supply chain.
Update: New Deadlines and Simplified Requirements
The current application deadlines are:
- December 30, 2026: generally applies to large and medium-sized enterprises, as well as to certain micro and small enterprises that are already subject to the existing EU Timber Regulation (EUTR)
- June 30, 2027: generally for the remaining micro and small businesses
In addition to the deadlines, the EU has also adjusted the responsibilities within the supply chain.
The central due diligence obligation and the submission of a Due Diligence Statement (DDS) focus more on the market participant (operator) who places a relevant product on the EU market for the first time or exports it from the EU. Downstream market participants and distributors are generally no longer required to submit their own DDS for products that are already covered accordingly. However, certain information, registration, and traceability obligations remain in effect.
There have also been changes to the scope of products covered. Therefore, you should not rely solely on a general product description to determine whether your goods are affected. The current version of Annex I of the EUDR and the customs tariff number listed therein are particularly important.
What is the EU Deforestation Regulation (EUDR)?
The Deforestation Regulation (Regulation (EU) 2023/1115, or EUDR for short) is intended to ensure that products containing certain raw materials do not contribute to deforestation or forest degradation.
The regulation covers seven commodity groups:
- Cattle
- Cocoa
- Coffee
- Oil palm
- Rubber
- Soy
- Wood
In addition to the raw materials themselves, numerous products manufactured from them may fall under the EUDR.
As a general rule, an affected product may only be placed on the market, made available on the market, or exported from the EU if it meets the requirements of the EUDR.
In particular, this means that the product:
- is deforestation-free,
- was produced in accordance with the relevant laws and regulations of the country of origin, and
- is covered by a statement of due diligence, to the extent necessary.
The key date for this is December 31, 2020. The relevant areas must not have been affected by deforestation or, in the case of relevant wood products, forest damage after that date.
Which products are covered by the Deforestation Regulation?
Whether a product falls under the EUDR cannot be determined solely on the basis of its material or product name.
The customs tariff numbers, or HS and CN codes, listed in Annex I of the EUDR are decisive.
This is important for online retailers. For example, a product may contain wood or rubber without automatically falling under the EUDR. Conversely, processed products may be covered.
You can find the official and current version of the regulation, including Annex I, on EUR-Lex.
The scope of the products has already been adjusted and may change further. Therefore, you should check the affected product lines using the current version of Annex I and the specific customs tariff code.
What does this mean for your product data?
For e-commerce companies, the quality of master data continues to grow in importance. For relevant product lines, you should clarify the following, among other things:
- What is the product’s tariff code?
- Does this item fall under Annex I?
- Which relevant raw material is included?
- Where was this raw material produced?
- What information and documentation has the supplier provided?
- Who assumes which EUDR role within the supply chain?
Especially when dealing with large product lines, it’s worth conducting this review in a structured manner and at an early stage.
Who is affected by the EUDR?
Specific responsibilities do not depend solely on the size of the company. The most important factor is the role your company plays within the supply chain.
Market participants—referred to as “operators” in the English regulation—play a central role. Simply put, this is a company that, as part of its business activities, places an EUDR-relevant product on the EU market for the first time or exports it from the EU.
An example
An online store based in Germany imports EUDR-regulated coffee directly from Brazil and then sells it in the EU.
The online store is a market participant in this supply chain. Therefore, it is responsible for fulfilling the corresponding due diligence obligations.
If, on the other hand, an online store purchases relevant products from an EU supplier who has already lawfully placed them on the EU market, its role is different.
The EUDR therefore also distinguishes between downstream operators and traders.
Under the simplifications adopted at the end of 2025, different obligations apply to them. As a general rule, they are not required to conduct the full due diligence process again for products that have already been covered, nor are they required to submit a separate DDS for the same goods.
However, certain information, registration, and traceability requirements remain in effect.
What does this mean, specifically, for online retailers?
Whether your online store is based in Germany, another EU country, or Switzerland is only one factor in the assessment.
The key factors are the product and the specific flow of goods.
Example 1: Your online store ships directly to the EU
Your company is based in Germany and imports a product subject to the EUDR directly from a third country.
If you are the first to place this product on the EU market, you are generally considered a market participant. This means that the key EUDR due diligence obligations fall on your company.
Example 2: Your online store makes purchases within the EU
You purchase a relevant product from an EU supplier who has already lawfully placed it on the EU market.
In that case, you are generally not the one who first places the product on the EU market. Depending on the specific circumstances, you may be considered, for example, a distributor or a downstream operator.
Example 3: Your Swiss online store sells to the EU
If you sell from Switzerland to customers in the EU, you should also review your import model.
Among other things, it is important to determine who acts as the importer at the time of import and who first places the product on the EU market.
Particularly in D2C and cross-border models, the contractual structure, the import model, and the roles of the companies involved can make a difference.
Therefore, the following applies to all three cases: Don’t just check whether your product falls under the EUDR. Also clarify your role in each relevant supply chain.
What is a due diligence statement?
For responsible market participants, one of the key requirements is due diligence. Depending on the product, this requires, among other things, information on its origin and the production areas. This may also include geolocation data.
Once the review is successful, the required Due Diligence Statement (DDS) is submitted via the EU’s EUDR Information System. The DDS is assigned a reference number. And this is exactly where the EUDR becomes relevant for shipping and customs processes.
New Requirement for Customs Clearance
To ensure that goods can continue to be cleared through customs without any problems, additional information will be required starting on the effective date:
- Precise customs coding at the item level (including Y and C codes)
- Due Diligence Statement (DDS) Reference Number: an electronic declaration that the goods are deforestation-free
The impact on the customs clearance process is independent of the general audit and reporting requirements under the EUDR. This means that, for customs clearance purposes, only the additional information required—such as the code and DDS reference number—is relevant. The audit and reporting obligations under the EUDR are separate from this and do not affect the customs clearance process.
What are Y and C codes?
The Y and C codes are document codes used in the customs declaration:
- Y-codes = Explanations or special cases. For example, Y141: Declaration that a company is claiming the SME exemption (through June 30, 2026) or Y133: Declaration that goods consist exclusively of recycled materials.
- C-codes = verification numbers. For example, the DDS reference number that confirms that a product is deforestation-free.
Why You Should Take Action Now
Even after the postponement, you shouldn’t put off your preparations until the end of 2026. Gathering data takes time, especially for larger product ranges and international supply chains.
First, check whether your products fall under Annex I of the EUDR based on their customs tariff code. If so, these four points are important:
- Determine Your Role: Determine what role you play in the flow of goods and which EUDR obligations apply to you as a result.
- Gather data: Make sure you have the necessary information and documentation from your suppliers. This may include origin and geolocation data.
- Organizing DDSs: Determine who is responsible for the due diligence review and the Due Diligence Statement (DDS), and how the DDS reference is assigned to the respective flow of goods.
- Prepare for Shipping and Customs: Make sure that DDS references and other required information for imports and exports are available. Coordinate with your customs and fulfillment partner to determine which data and TARIC codes are required for your goods flow.
Our tip: Start with your product lineup. Only once you’ve determined which products are actually affected should you review the remaining processes in detail. If you have any questions about shipping and customs, MS Direct is here to help.
EUDR, Shipping, and Customs: MS Direct Is Here to Help
The EUDR is complex. But for online retailers, it doesn’t have to be any more complicated than necessary. MS Direct combines fulfillment and cross-border logistics with its own customs expertise. We help you determine what information is relevant for your imports and exports and how it needs to be integrated into the shipping and customs process. This applies to both online stores and brands based in the EU as well as Swiss companies that sell to the EU.
Not sure whether the EUDR will affect your shipping or customs processes? Talk to us. We’ll take a look at your specific flow of goods.
Additional 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
As of August 2026. The regulatory and technical requirements under the EUDR may continue to evolve. In particular, with regard to the scope of products, customs tariff codes, and technical specifications, you should verify the current status of EU regulations before implementation.