EUDR and exports: does it apply outside the EU market?

Yes. The EUDR bars exporting a relevant product from the EU, not only placing it on the EU market, unless it is deforestation-free, legally produced, and covered by a due diligence statement. A business that is first to export one out of the Union carries the same due diligence duty as an importer bringing one in.

Why the regulation covers exports at all

The EUDR's own title gives this away: it is a regulation "on the making available on the Union market and the export from the Union" of relevant commodities and products. Article 3 sets out the prohibition in those terms directly — a relevant commodity or product shall not be placed on the market, made available on the market, or exported, unless it is deforestation-free, was produced in line with the relevant legislation of the country of production, and is covered by a due diligence statement.

The logic is straightforward once you see it: the regulation exists to stop EU demand from driving deforestation, and demand runs both ways. An EU roaster who buys Brazilian coffee and sells it on to the UK or the US is still the reason that coffee was grown. Treating exports as out of scope would have left an obvious gap for anything the EU imports, processes and re-sells onward rather than consuming itself.

Who counts as an exporter under the regulation

"Export" here has the narrow customs meaning: the customs procedure of releasing goods for export from the EU's customs territory to a destination outside it. Two situations trigger it:

• You are the first to place the product on the EU market, and you then export it. A UK furniture importer who buys EU-grown oak, has it machined domestically, and ships the finished pieces to the US is both the primary operator (on the way in, if the timber itself entered the EU as a relevant product) and the exporter (on the way out).
• You export a product someone else already placed on the EU market. A trading house that buys cocoa butter already in free circulation in the EU and ships it to a non-EU buyer is exporting, even though it never imported the raw cocoa itself.

In both cases the obligation sits with whoever carries out the export customs declaration, not with whoever merely arranges freight. A freight forwarder or logistics provider acting only on instructions is not the operator; see our guide on freight forwarders' and carriers' duties for where that line falls.

What an exporting business has to prove

Exactly what an importer has to prove, applied to the outbound consignment:

1. Deforestation-free — the relevant commodity in the product was not grown on land deforested or degraded after 31 December 2020.
2. Legally produced — production complied with the laws of the country of production that apply to land use, environmental protection, labour and land rights, among others.
3. Covered by a due diligence statement (DDS) — submitted through the EU's TRACES system before the goods are released for export, carrying traceability information down to plot level for most commodities (see the four-hectare geolocation rule for the thresholds).

If you are the first operator to place the product on the EU market and you export it yourself, you are not filing twice. One due diligence exercise and one DDS cover the product; the export declaration references the same statement rather than requiring a fresh one, provided nothing about the product's deforestation-free status has changed since it was placed on the market.

Operator, exporter or downstream trader: a quick table

Situation	Role under EUDR	Files a new DDS?	What you reference instead
First to place the product on the EU market, and later exports it unchanged	Primary operator (export leg)	Yes, once	Not applicable — you hold the original reference
Buys a product already placed on the EU market by someone else, then exports it	Downstream operator / exporter	No	The DDS reference number already attached to the consignment
Only arranges carriage, customs clearance or freight on another party's instructions	Neither operator nor trader	No	Not your obligation — it sits with your client
Exports goods that never cleared EU customs (transit, free zone, bonded warehouse)	Outside EUDR at that stage	No	See our guide on free zones and re-exports

The 2025 amendment (Regulation (EU) 2025/2650) simplified the downstream case specifically: an operator who is not the first to place a product on the market, and who is only re-exporting or further distributing it, no longer has to repeat full due diligence from scratch — they can rely on the upstream DDS reference, provided they have no reason to doubt it. Our guide on downstream operators' and traders' obligations covers what "reason to doubt it" means in practice.

Which deadline applies to an exporting business

The same application dates apply to the export obligation as to everything else in the regulation, set by your size band and product, not by which direction the goods are moving:

• 30 December 2026 — large and medium operators and traders, and micro or small operators whose products were already covered by the EU Timber Regulation.
• 30 June 2027 — micro and small operators and traders on non-timber products.
• 30 December 2027 — products newly brought into Annex I scope by Commission Delegated Regulation (EU) 2026/2102 (certain palm oil derivatives, soluble coffee and frozen cattle tongues among them), regardless of operator size.

Size is assessed at the level of the company carrying out the export, using the Accounting Directive thresholds — see micro and small operator simplifications if you are close to a size boundary. As of this run, no further postponement beyond these dates has been adopted; the Commission's simplification review published in May 2026 narrowed some obligations but did not reopen the application dates themselves.

What happens if you export without a due diligence statement

Member state competent authorities can stop a consignment at the export customs point exactly as they can stop one on import, and the same penalty regime in Article 25 applies: fines of up to 4% of the operator's EU-wide annual turnover, confiscation of the goods or the revenue from them, and temporary exclusion from public procurement and from the EU market for repeat offences. See what non-compliance actually costs for how that scales by size of business. Customs systems check for a valid DDS reference at the point of export declaration the same way they do at import, so a missing or invalid reference can hold a shipment at the border rather than surface only later in an audit.

If you are ready to work out whether this applies to your business and by which date, run the free check — it asks about your role, size and commodities and gives you a deadline and obligation list specific to your situation.

Frequently asked questions

Does EUDR apply if I only sell to customers outside the EU?

If the product you are exporting is a relevant commodity or product under Annex I, yes. The destination of the sale does not take it out of scope — what matters is whether a relevant product leaves the EU's customs territory under an export procedure, which brings the due diligence and DDS requirements with it.

Do I need a new due diligence statement for every export shipment?

You need a valid DDS reference attached to the consignment, but if you already hold one from when the product was placed on the EU market and nothing material has changed, you reference that statement rather than filing a new one. A genuinely new due diligence exercise is only needed if you are the first to place the product on the market as part of the export itself.

What if I am exporting a product that was always outside the EU market, such as goods in transit?

Goods that never clear EU customs into free circulation — held in a free zone, bonded warehouse, or under a transit procedure before moving straight on — are outside the EUDR at that stage. Our guide on free zones, transhipment and re-export obligations explains the customs triggers in detail.

Does the exporter or the freight forwarder carry the obligation?

The exporter — whoever is named as the declarant on the export customs declaration, or on whose behalf it is made. A freight forwarder or carrier acting purely as an agent on instructions does not become an operator or trader under the EUDR.

Is a UK or US business that buys from an EU exporter affected by EUDR itself?

No, not directly. EUDR is EU law and binds the EU-established business doing the exporting. The non-EU buyer may have its own due diligence expectations under other schemes, but the EUDR's obligations, deadlines and penalties apply to the EU operator or trader on this side of the transaction.

Does the size of the company I'm exporting to change my deadline?

No. Your application date is set by your own size band as the exporting operator or trader, not by the size of your counterparty or customer.

Can I rely on the deforestation-free assessment my supplier already did when I export the product on?

If you are a downstream operator and the product's due diligence statement and reference number already exist from when it was first placed on the EU market, you can rely on that reference rather than redoing the full assessment, provided you have no information suggesting it is inaccurate or that the product is no longer deforestation-free.

Where do I submit the due diligence statement for an export?

Through TRACES NT, the same EU information system used for imports, before the goods are released under the export customs procedure. See the TRACES due diligence statement, step by step for the submission process itself.