EUDR forest definition: what counts as deforestation and forest degradation under Article 2

Under Article 2 of Regulation (EU) 2023/1115, "forest" is land over 0.5 hectares with trees taller than 5 metres and canopy cover above 10%, or land that could reach those thresholds in situ; "deforestation" is any conversion of that forest to agricultural use, human-induced or not; "forest degradation" is a narrower, structural change — primary or naturally regenerating forest turned into plantation forest, planted forest or other wooded land. These three definitions, not a general sense of "harming forests", decide what the regulation actually catches.

That precision matters because the EUDR does not ban harming forests in general. It bans placing products on the EU market, or exporting them, if they are linked to deforestation or (for timber only) forest degradation that happened after 31 December 2020. Everything turns on whether the specific land involved meets the Article 2 definition of "forest" in the first place, and whether what happened to it meets the definition of "deforestation" or "degradation".

What counts as "forest" under Article 2

Article 2(4) sets a five-part test. Land is forest if, at the same time, it is:

• larger than 0.5 hectares,
• covered by trees taller than 5 metres (or able to reach that height in situ),
• with canopy cover above 10% (or able to reach that in situ),
• not predominantly under agricultural or urban land use, and
• not an agricultural plantation.

This is the FAO forest-resource-assessment threshold, carried into EU law. It is a low bar: 0.5 hectares is roughly half a football pitch, and 10% canopy cover is sparse. Degraded or young regrowth can still count as forest if the trees are capable of reaching the height and cover thresholds where they stand.

Article 2(4) also lists what is included even though it might look like an interruption in forest cover: forest roads, firebreaks and other small open areas, forest in national parks and protected areas, windbreaks and shelterbelts of trees above 0.5 hectares, mangroves in tidal zones regardless of whether they are classified as a land or water area, nurseries of forest species within forest, and areas temporarily unstocked due to harvesting or natural causes that are expected to regenerate.

"Agricultural plantation" is defined separately and excluded from "forest": tree stands in agricultural production systems such as fruit tree orchards, oil palm plantations, olive orchards and agroforestry systems where crops grow under tree cover. This exclusion is what keeps a palm oil estate or a coffee agroforestry plot out of the forest definition even though it has a tree canopy — it is also why operators sourcing from mixed agroforestry systems need to check the land classification carefully, not assume tree cover means forest.

Term	Article	Core test
Forest	2(4)	0.5+ ha, trees 5m+, canopy 10%+, not agricultural/urban, not an agricultural plantation
Agricultural plantation	2(5)	Tree stand managed as part of an agricultural production system; excluded from "forest"
Deforestation	2(3)	Conversion of forest to agricultural use, whether human-induced or not
Forest degradation	2(7)	Structural change: primary/naturally regenerating forest into plantation forest, planted forest, or other wooded land
Natural forest	2(6)	Umbrella term for primary forest and naturally regenerating forest
Primary forest	2(6)	Naturally regenerated, native species, no clearly visible indication of human activity, ecological processes not significantly disturbed

What counts as "deforestation"

Article 2(3) defines deforestation as the conversion of forest to agricultural use, whether human-induced or not. Two things in that sentence do a lot of work.

First, "agricultural use" is broad: it covers land used for raising livestock, or for growing agricultural commodities including agricultural plantations and land set aside under the EU's agricultural support rules. Clearing forest for a soya field, a cattle pasture or a new oil palm plantation is deforestation regardless of who authorised it or whether it was legal under local law.

Second, "whether human-induced or not" means natural disturbance is not automatically an escape. If a forest burns and the land is then converted to cropland, that conversion is deforestation under the regulation, even though the fire itself was natural. The relevant act is the conversion to agricultural use, not the cause of the initial disturbance. A fire that burns forest which is then left to regenerate as forest, with no change of use, is not deforestation on its own.

Deforestation is assessed against the cut-off date of 31 December 2020, set by Article 3. Land that was already in agricultural use before that date, and has stayed in agricultural use, is not a compliance problem under the EUDR even if the original clearing happened decades ago. The regulation looks forward from the cut-off, not backward indefinitely.

What counts as "forest degradation" — and why it is narrower

Forest degradation, defined in Article 2(7), is structural changes to forest cover, taking the form of the conversion of primary forests or naturally regenerating forests into plantation forests or other wooded land, or of primary forests into planted forests.

The key distinction is forest remaining forest, but of a lesser ecological kind. A primary forest of mixed native species that is logged and replanted as a single-species pine plantation has not been deforested — it is still land with trees — but it has been degraded under Article 2(7), because a primary or naturally regenerating forest has been converted into a plantation or planted forest.

Degradation only bites on the "deforestation-free" test for timber and timber products. Article 2(13) defines "deforestation-free" as meaning, for wood and wood products, that the wood was harvested without causing forest degradation after 31 December 2020, as well as without causing deforestation. For the other six commodities — cattle, cocoa, coffee, oil palm, rubber and soya — only the deforestation limb applies; degradation of forest that is not converted to agricultural use is not, on its own, a bar for those commodities.

Routine, well-managed harvesting of a plantation that was already a plantation before the cut-off date is not degradation — there is no conversion from primary or naturally regenerating forest, because it was not that to begin with. The European Commission's EUDR guidance document also draws a causal distinction: degradation requires that the harvesting activity itself induces the structural change. Where a forest is damaged by a storm, fire or pest outbreak and the subsequent harvest is salvage or sanitary felling intended to remove dead or diseased timber rather than to convert the land to another forest type, the Commission's guidance treats that as not inducing degradation, provided the operator can document the actual purpose of the felling. That guidance interprets Article 2(7); it has not changed the wording of the article itself, and operators relying on it should keep records showing why a harvest happened, not just what was harvested.

Primary forest, naturally regenerating forest, and planted forest

Article 2(6) uses "natural forest" as an umbrella term covering two categories:

• Primary forest: naturally regenerated forest of native tree species, where there are no clearly visible indications of human activity and the ecological processes are not significantly disturbed.
• Naturally regenerating forest: forest predominantly composed of trees established through natural regeneration. This includes forest where it is not possible to distinguish whether it was planted or naturally regenerated, and coppice from trees that were originally established through natural regeneration.

Against these, a planted forest is predominantly composed of trees established through planting or deliberate seeding, and a plantation forest is a planted forest that is intensively managed and meets further criteria at planting and maturity — uniform species, even age class, and regular spacing — set out in the regulation. Degradation is the move from the first category to the second: native, naturally established forest converted into something planted and managed.

This distinction is also why the regulation treats timber differently throughout. A plantation forest that was already a plantation before the cut-off date generates deforestation-free timber as long as the land itself was not converted from forest to agricultural use, and the degradation test cannot apply retroactively to land that was never primary or naturally regenerating within the relevant period.

How this interacts with the geolocation and risk-assessment obligations

The forest definition is not just an academic point — it decides what geolocation data an operator actually needs to collect. The 4-hectare threshold that decides whether a plot needs a single point or a full polygon (see our guide on geolocation requirements) is a separate, larger threshold from the 0.5-hectare minimum that makes land "forest" in the first place. A plot can clear the 0.5-hectare forest threshold and still only need a point if it is under 4 hectares.

Risk assessment obligations under Article 10 also hinge on this definition: an operator has to assess whether the specific plot of land was forest, by the Article 2(4) test, on 31 December 2020, and whether it has since been converted or degraded. Our guide to risk assessment and mitigation covers what competent authorities expect that assessment to look like in practice, and our guide to filing a due diligence statement in TRACES covers what you then have to submit.

For timber and furniture importers specifically, the degradation test is the main source of extra complexity compared with the other six commodities, because it requires evidence about forest type and history, not just land-use conversion. Our guide for furniture and timber importers sets out what that means in practice now that the EU Timber Regulation has been repealed and folded into the EUDR.

What has not changed

Regulation (EU) 2025/2650, which postponed the application dates and introduced the simplified regime for micro and small operators, did not amend the Article 2 definitions of forest, deforestation, forest degradation, primary forest or planted forest. Our guide to what changed under 2025/2650 covers what that amendment actually touched — mainly timing and operator categories, not the substantive scope tests. If you are checking whether your own product and supply chain fall under the regulation at all, start with the EUDRCheck tool, which applies these definitions to your answers rather than asking you to interpret Article 2 yourself.

FAQ

Does a tree plantation count as forest under the EUDR? It depends on management intensity and whether it is an agricultural plantation. A plantation forest — intensively managed, even-aged, regularly spaced — is still "forest" under Article 2(4) if it meets the size, height and canopy thresholds; an agricultural plantation such as an oil palm estate or fruit orchard is excluded from the forest definition by Article 2(5). The distinction matters because converting forest, including plantation forest, to an agricultural plantation after the cut-off date can itself be deforestation.

Is logging automatically forest degradation under the EUDR? No. Harvesting timber from land that stays forest afterwards, including regeneration after felling, is not degradation on its own. Degradation requires a structural change — primary or naturally regenerating forest being converted into plantation forest, planted forest or other wooded land. Land that is already a plantation and is harvested and replanted as the same type of plantation is not being degraded further under Article 2(7).

Does forest degradation affect commodities other than timber? No, under the current text. The "deforestation-free" definition in Article 2(13) applies the degradation test only to wood and wood products. Cattle, cocoa, coffee, oil palm, rubber and soya are assessed only against the deforestation (land-use conversion) test, not against forest degradation.

What is the minimum size of land that counts as forest under the EUDR? 0.5 hectares, with trees capable of reaching 5 metres in height and 10% canopy cover. This is smaller than the 4-hectare threshold that decides whether geolocation data needs to be a single point or a full polygon — those are two different thresholds doing two different jobs.

Does a fire that damages a forest count as deforestation? Not by itself. Deforestation is the conversion of forest to agricultural use. A forest that burns and is then left to regenerate as forest has not been deforested. If the burnt land is instead converted to cropland or pasture after 31 December 2020, that conversion is deforestation, regardless of whether the fire that preceded it was natural or started deliberately.

Can salvage logging after a storm count as forest degradation? The European Commission's guidance treats salvage harvesting after storm or fire damage, and sanitary felling to control pests or disease, as not "inducing" degradation under Article 2(7), provided the operator can document that this was the actual purpose of the felling. This is Commission interpretive guidance rather than a change to the wording of the regulation, so keep records of why a harvest happened in case an authority asks.

Where exactly is the forest definition written down? Article 2 of Regulation (EU) 2023/1115, as published on EUR-Lex. Paragraph 4 defines forest, paragraph 3 defines deforestation, paragraph 7 defines forest degradation, and paragraph 6 defines natural forest and primary forest. None of these paragraphs has been amended by the later Regulation (EU) 2025/2650.

Does an agroforestry system with scattered trees count as forest? Usually not, if it is managed as part of an agricultural production system — Article 2(5) excludes agricultural plantations, including agroforestry systems where crops are grown under tree cover, from the forest definition. Whether a specific plot counts depends on how it is actually managed and classified, not just on tree density, so this is worth checking plot by plot rather than assuming by commodity.