The EUDR Regulation and the Important Date of December 30, 2026

Newsletter 09/2026: The EUDR Regulation and the Important Date of December 30, 2026

Effective December 30, 2026, the deferred EU Deforestation Regulation (EUDR) will take effect. For importers, this means one crucial thing: without a due diligence declaration number, customs authorities will not release the goods in question into free circulation.

Does this apply to you and your imports as well?

Probably yes, if you import any of these commodities or products made from them:
 
    Conversely, the regulation does not apply to, for example, cowhide, used goods, test samples,  waste, bamboo, and packaging that merely protects or carries other goods and is imported along with them.

The customs/HS code is what matters, not what you call the goods. Some products fall under the regulation, others do not, and sometimes a single “ex” in the code makes all the difference. A complete overview of the codes in a single, definitive list is practically nonexistent. As is often the case with similar regulations, you must actively determine for yourself whether it applies to you or not. There are several ways to do this:

Annex I of the regulation on EUR-Lex: The only legally binding list. The original regulation was revised, and some HS codes were removed (e.g., leather). Here is a link to the consolidated version, which should reflect these changes: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02023R1115-20260918

Customs Administration, TARIC CZ application: Enter your specific 10-digit code, and TARIC will show you whether an EUDR certificate is required for that code (C716, or Y-series exemptions, as applicable). This is the most important information for you as an importer, because the customs system makes decisions based on TARIC, not on Annex I, and the Customs Administration itself cites TARIC as the method for incorporating EUDR requirements. The disadvantage is that you have to search by individual codes. Furthermore, according to sources, the EUDR is being incorporated into TARIC on an ongoing basis (the Commission’s latest revision is dated September 23, 2026). https://celnisprava.gov.cz/cz/aplikace/Stranky/taric-cz.aspx
 
 

 

Starting when, and keep an eye out for shipments in transit

The regulation will take effect on December 30, 2026. However, the decisive factor is the date of release for free circulation, not the date the goods were shipped. This means that the EUDR may, in practice, already apply to containers and individual shipments loaded in Asia in late October. It is therefore advisable to handle the documentation sooner rather than later and to take this new regulation into account right from the start of the supply chain.

Only importers who are individuals or micro and small enterprises—and who were already classified as such as of December 31, 2024—are granted a deferral until June 30, 2027. This does not apply to goods that were already covered by the earlier Timber Regulation (EUTR), such as lumber, boards, or pallets.

How does this work in practice? New businesses established after December 31, 2024, are subject to the requirement regardless of size. At the same time, the original EUTR applies to all businesses regardless of size and date of establishment:

 

  • The EUTR (Regulation No. 995/2010) is an older regulation that applies only to wood. This requirement has been in effect for several years and mandates proof of the legality of the wood’s origin.

  • The EUDR (Regulation 2023/1115) is a new regulation that replaces the EUTR. Additionally, it requires that goods not originate from deforested land and mandates geolocation and declarations within the information system.

 

What should you do and find out? 

1) Check the codes for your goods (see above); if necessary, we’ll be happy to help you.
 
2) Register in the EU information system (TRACES). You’ll need an EORI number.
 
3) Request the following documentation from your supplier: a description of the goods, net weight, country of origin, production period, and coordinates of the land where the goods were produced (a single point for plots up to 4 ha, a polygon for larger plots), as well as proof that the goods were produced legally and that the land was not deforested after December 31, 2020.
 
4) Submit a due diligence declaration in the information system before the goods are released. You will receive a reference number. The declaration is submitted by the importer, not the foreign supplier.
 
5) Send us the reference number before filing the customs declaration. We will enter it along with the C716 document code (or C717 for the simplified declaration for small primary producers). Without it, the customs declaration will not be accepted.
 
As you can see, it really doesn’t pay to put off obtaining the necessary documents, since it’s a lengthy process. However, without the final step—the reference number—you cannot file a customs declaration. We probably don’t even need to mention the risks of storage fees, demurrage, and detention for goods held up in this way, but we’d rather do so anyway.
 
A single customs declaration can include multiple numbers. A single number can cover multiple shipments until the declared quantity is exhausted.
 
If the goods are not covered by the regulation or are subject to an exemption (samples, used goods, recycled materials, packaging), we need to know this in advance. Even in such cases, a special code (Y series) must be entered in the customs declaration; otherwise, the declaration will not be accepted.
An important point to note is that the declaration can be corrected or withdrawn within 72 hours of the number being issued. Once the number is used in the customs declaration, this is no longer possible. Therefore, please check the information carefully.
 

 

What if I don't comply with the regulation?

The most common consequence is probably clear and immediate. The goods are not released, and the shipment gets stuck somewhere. You don’t have the goods, but you’re incurring additional costs for customs warehousing or even demurrage and detention—and as we know, that’s no small expense. In addition, the regulation provides for penalties. Placing goods on the market in violation of the regulation may result in a fine of up to 5 million CZK, and up to 10 million CZK for repeat offenses. For legal entities, the fine may amount to up to 4% of annual turnover in the EU. In addition, the goods may be confiscated, and the entity may be barred from public procurement for up to 12 months.

 

The eSTONE app and EUDR 

For customers with access to eSTONE, the “Customs Analysis” section under Reports includes not only the CBAM and EU Market Protection tabs but also the EUDR tab, where we continuously update the HS codes. This allows you to easily determine which of your imports are affected by the regulation all within a single system.
 
If you do not have access to eSTONE or the Reports section, please contact us, and we will resolve the issue immediately.
 
 
Please also feel free to contact us with any questions; we’ll be happy to assist you with this matter or help you find the right support.

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