From 30 December 2026 the essential obligations under Regulation (EU) 2023/1115 on deforestation-free products (EUDR) will apply.
According to the regulation, so-called relevant products can only be placed on the market, made available on the EU market and exported from the EU if they meet a total of three conditions:
- are deforestation-free, i.e. the raw material comes from land that has not been deforested after 31 December 2020;
- have been produced in accordance with the laws of the country of production (m.in. land rights, environmental protection, labour rights, taxes and duties);
- are covered by a due diligence statement (DDS) submitted to the Union Information System (with some possible simplifications).
The regulation covers seven raw materials: cattle, cocoa, coffee, oil palm, rubber, soybeans and wood, as well as products made from them listed in Annex I (e.g. beef, chocolate, furniture, paper, tyres). Whether a good is subject to the EUDR is determined by its CN code compared to Annex I, and not by the use of the raw material itself. The rules apply to both imported and manufactured goods in the EU.
Responsibilities based on your role in the supply chain
Following the amendment made by Regulation (EU) 2025/2650, the obligations depend on the role of the entrepreneur:
- the entity that first places the product on the market in the EU or exports it, collects information about the product (including geolocation data of the plots where the raw material was produced), assesses and, if necessary, mitigates the risk, and then submits a DDS (due diligence statement (Article 4(2) EUDR));
- Downstream and commercial operators who process or sell products already placed on the market do not submit a DDS, but store data on suppliers and recipients for 5 years (only the first one obtains a DDS); non-SME entities register in the system;
- A micro and small primary entity from a low-risk country submits a one-off, simplified declaration covering the estimated annual quantity of products.
Poland, like other EU countries, has been classified as a low-risk country (Commission Implementing Regulation (EU) 2025/1093). This allows for the use of simplified due diligence (without risk assessment and mitigation), but only for raw materials from low-risk countries, where the country of origin of the raw material is important, not the seller’s headquarters.
Key terms
- 30 December 2026 – large and medium-sized enterprises;
- 30 December 2026 – micro and small for timber products covered by the EUTR so far;
- 30 June 2027 – Other micro and small enterprises (established as such by 31 December 2024) and natural persons;
- 30 December 2027 – products newly added to Annex I.
New product catalog
Delegated Regulation (EU) 2026/2102, effective from 18 September 2026, reworked Annex I. Cowhides, retreaded tyres, conveyor belts, soybeans, and car and aircraft seats, m.in were excluded from the scope of the EUDR. From 30 December 2027, the regulation will cover, m.in, instant coffee, frozen beef oil, soaps and a number of palm oil derivatives (e.g. alcohols and fatty acids). In the case of some of the new items (“ex”), the method of production is decisive, e.g. with the use of oil palm, so the change also affects the chemical and cosmetics industries.
Supervision and sanctions in Poland
Control bodies and penalties will be determined by a national law. Its draft (UC101, last version of 26 August 2026) has still not been adopted by the government. The draft provides that:
- the inspection will be carried out by the Veterinary Inspection (cattle), IJHARS (cocoa, coffee, oil palm, soybean) and the Environmental Protection Inspectorate (wood, rubber), and the Head of the National Tax Administration is to provide them with quarterly lists of importers and exporters;
- penalties will reach 4% of annual turnover in the EU for systemic breaches, 1% for procedural breaches and 4-6% of turnover under collective liability;
- the authority will be able to seize the goods, and the customs authority will be able to refuse to release them for circulation or export; in the event of a recidivism, a temporary ban on trade will be possible;
- it will not be possible to obtain an individual ruling in EUDR cases.
We recommend a final verification of your organization’s readiness to potentially meet these obligations.
