EUDR vs CBAM: how the two EU import rules differ

No — the EUDR and the Carbon Border Adjustment Mechanism (CBAM) are entirely separate EU regulations with no shared products. The EUDR polices seven deforestation-linked commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood. CBAM prices embedded carbon in six industrial goods: iron and steel, aluminium, cement, fertilisers, hydrogen and electricity. A business can face one, both, or neither — but never through the same product line, because the two lists of goods do not intersect at all.

The confusion is understandable. Both regulations are enforced partly through the customs declaration, both introduced new "declarant" or "statement" paperwork within the same 18-month window, and both get shortened to a four-letter acronym that import and customs teams now hear in the same breath. This guide sets out what each one actually requires, so you can tell which applies to your goods — and stop assuming the other one does too.

What each regulation actually does

The EUDR — Regulation (EU) 2023/1115, as amended by Regulation (EU) 2025/2650 — stops deforestation-linked products reaching the EU market. It requires the operator placing a relevant commodity on the market to file a due diligence statement showing the product was not grown on land deforested or degraded after 31 December 2020, and was produced legally in its country of origin. The mechanism is geolocation, risk assessment and a statement filed in the EU's TRACES system.

CBAM — Regulation (EU) 2023/956, as amended by the CBAM Omnibus Regulation (EU) 2025/2083 — makes importers of carbon-intensive goods pay the same carbon cost that EU producers already pay under the EU Emissions Trading System (EU ETS). It requires an authorised CBAM declarant to report the embedded emissions in imported goods and buy and surrender CBAM certificates to cover them, priced against the weekly average auction price of EU ETS allowances. The goal is carbon-price parity, not supply-chain legality — CBAM does not ask where a shipment of steel was mined, only how much carbon went into making it.

Which goods are covered — and why there's no overlap

The EUDR's Annex I list is agricultural: cattle, cocoa, coffee, oil palm, rubber, soya, wood, and specified derivatives of each (leather, chocolate, furniture, tyres, palm-based chemicals and so on). CBAM's Annex I list is industrial: cement, iron and steel, aluminium, fertilisers, hydrogen and electricity, plus a defined set of precursor and downstream goods within those sectors (certain screws, bolts, structures, and iron- or steel-containing articles).

Wood pellets, biomass and bioenergy sit under the EUDR, not CBAM — CBAM has no forestry or biomass category at all, however carbon-relevant the product might sound. The reverse also holds: a shipment of structural steel or aluminium extrusions has no EUDR exposure whatsoever, however large the consignment. If you handle both kinds of goods, you are running two compliance systems side by side, not one system that happens to cover both.

Timelines compared: both land in the same 18 months

This is the real source of the confusion — not shared goods, but a shared calendar.

	EUDR	CBAM
Governing text	Regulation (EU) 2023/1115, as amended by (EU) 2025/2650	Regulation (EU) 2023/956, as amended by (EU) 2025/2083
Goods covered	Cattle, cocoa, coffee, oil palm, rubber, soya, wood (and derivatives)	Iron & steel, aluminium, cement, fertilisers, hydrogen, electricity
What it tests	Deforestation-free status since 31 Dec 2020, and legality of production	Embedded carbon emissions in the imported good
De minimis threshold	None by product — size affects obligations and date, not whether you're in scope	50 tonnes per importer per year (not hydrogen or electricity)
Definitive regime starts	30 December 2026 (large/medium, and micro/small already under the EU Timber Regulation); 30 June 2027 (other micro/small)	1 January 2026
Authorisation/registration deadline	Not applicable — filed per consignment or general statement, no standing authorisation	31 March 2026 to apply for Authorised CBAM Declarant status
What you file	Due diligence statement (DDS) in TRACES, referenced on the customs declaration	Quarterly emissions reports, then annual CBAM declaration with certificates surrendered
First major filing deadline	DDS reference required from each operator's applicable date above	First annual CBAM declaration, covering 2026 emissions, due 30 September 2027
Enforcement	National competent authority designated under EUDR Article 14, working with customs under Articles 26–27	National customs authority, via the CBAM registry

CBAM's definitive regime is already running — it started on 1 January 2026 — while the EUDR's main date is still ahead, on 30 December 2026. A business that only started hearing about CBAM obligations in early 2026 can easily assume the EUDR works the same way, on the same clock, when in fact the two deadlines are a full year apart and govern completely different goods.

What you file, and who checks it

Under the EUDR, the operator placing a relevant product on the market files a due diligence statement, gets a reference number from TRACES, and puts that reference on the customs declaration. How that reference number interacts with customs clearance is covered in detail elsewhere on this site — in short, customs will not release a consignment without a valid reference, but customs itself does not assess deforestation risk; that sits with the national competent authority.

Under CBAM, an importer (or their indirect customs representative) must hold Authorised CBAM Declarant status before importing in-scope goods above the 50-tonne threshold. That status is applied for through a member state's CBAM authority, not TRACES. Once authorised, the declarant reports embedded emissions quarterly and files one annual CBAM declaration, settling the certificate obligation for the year. There is no equivalent to the EUDR's geolocation or legality test anywhere in this process — CBAM certificates respond to tonnes of CO2, not land use.

The 50-tonne CBAM threshold vs EUDR's no-minimum rule

CBAM Omnibus Regulation (EU) 2025/2083 introduced a 50-tonne-per-year de minimis threshold, measured per importer, for iron and steel, aluminium, fertilisers and cement. Importers below that line are relieved of CBAM's substantive obligations and simply mark their customs declaration as an "occasional CBAM importer" — no authorisation, no certificates, no emissions reporting. Hydrogen and electricity have no equivalent carve-out; every import of those two goods stays in scope regardless of volume.

The EUDR has no comparable volume threshold. Size affects which obligations apply and which of the two application dates you get — see the EUDR deadline guide for which date applies to you — but a micro business importing a single pallet of coffee is in scope of the EUDR in exactly the way a large importer is, just with simplified due diligence and, usually, more time. Do not read CBAM's de minimis exemption across to the EUDR: there is no low-volume EUDR exemption to mirror it.

Could CBAM's scope ever reach EUDR commodities?

No proposal currently on the table would do that. The Commission's December 2025 proposal to widen CBAM adds roughly 200 further downstream products — understood to be goods made predominantly from the metals already in scope, such as additional finished steel and aluminium articles — and would take effect from 1 January 2028 if adopted. As of this guide, it remains a proposal, not adopted law, and nothing in it reaches agricultural commodities, wood, rubber or any other EUDR good. The two regulations' product lists have been extended independently of each other so far, and have stayed on opposite sides of the agricultural/industrial line each time.

If your business deals in both kinds of goods

A diversified importer or trading house — bringing in, say, tropical timber and structural steel through the same logistics operation — needs two separate compliance builds, because nothing about either regulation lets a system built for one substitute for the other:

• Separate registrations: a TRACES operator profile for EUDR filings, and Authorised CBAM Declarant status (if above the 50-tonne threshold) for CBAM.
• Separate data: geolocation and supplier legality data for the EUDR; embedded-emissions data, usually sourced from supplier emissions reports or default values, for CBAM.
• Separate customs fields: a DDS reference number for EUDR-covered consignments, and CBAM declarant and goods-classification data for CBAM-covered ones. The same shipment will never need both, because no single CN code sits in both Annex I lists.
• Separate deadlines to track, on the calendar above — missing one does not affect your standing under the other.

This is the same practical point that applies to the EUDR's overlap with CSRD reporting and the CSDDD: overlapping acronyms and overlapping timelines do not make the underlying obligations interchangeable. Build each compliance process on its own regulation's actual test, not on a general sense that "the EU import rules" are one thing.

What to do now

If your goods are agricultural — cattle, cocoa, coffee, oil palm, rubber, soya or wood — CBAM has no bearing on you at all; your obligations run entirely through the EUDR, and the EUDR deadline guide sets out which of the two application dates applies to your business. If your goods are iron, steel, aluminium, cement, fertilisers, hydrogen or electricity, the reverse is true: CBAM is your regulation, and the EUDR has nothing to say about your imports.

If you handle both, treat them as two unconnected compliance programmes run by two different teams against two different calendars, not one combined "EU import compliance" project. Run your business through the checker to get a dated plan for your actual EUDR obligations, separate from whatever your CBAM position already requires.