On 30 December 2026 the due diligence obligations of the EU Deforestation Regulation start to apply to large and medium-sized operators (Regulation 2025/2650). From that day on, every consignment of an affected product comes with a due diligence statement, and its reference number is available to the customs authorities before release (Regulation 2023/1115). Little of this shows up in the shop. Behind it, in the ERP, a great deal changes: country of production, geolocation, quantity in net mass and the number of the statement become fields of the article and line master that an interface has to carry.
Key takeaways
- The deadline has moved, it has not gone away. Articles 3 to 13, 16 to 24, 26, 31 and 32 apply from 30 December 2026 (Regulation 2025/2650). The original text named 30 December 2024, the first postponement 30 December 2025 (Regulation 2024/3234). Both dates still appear in many guides.
- Micro and small enterprises have a date of their own: 30 June 2027, and only for enterprises established as such on 31 December 2024 (Regulation 2025/2650). Changing size class later does not automatically move a company into the later deadline.
- Article 9 paragraph 1 requires eight records per product, among them country of production, quantity in kilograms of net mass and the geolocation of every plot with at least six decimal digits (Regulation 2023/1115). These are master data fields, not attachments.
- The due diligence statement produces a reference number. It travels to downstream operators and traders and has to reach customs before release for free circulation (Regulation 2023/1115). Keeping it in a comment field means losing it in the customs declaration.
- Product passport and packaging data do not help here. The data carrier of the digital product passport holds a product identifier (Regulation ESPR 2024/1781), the packaging marking from 12 February 2027 shows the waste regime (Regulation PPWR 2025/40) - neither of them carries a reference number of a due diligence statement.
What actually begins on 30 December 2026
The Deforestation Regulation covers seven commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood (Regulation 2023/1115). It captures not only the commodities themselves but also products that contain them, have been fed with them or have been made using them. For a merchant selling furniture, paper goods, leather articles, tyres or food this means: Annex I decides, not the product group in the in-house catalogue. The assignment runs through the Harmonised System code, and that code sits in the ERP - if it is maintained there.
The substantive benchmark is the cut-off date of 31 December 2020: deforestation-free means the commodities were produced on land that has not been deforested after that date (Regulation 2023/1115). The regulation is therefore not a forecast but a look back at a fixed point in time. The legislator quantifies the reason itself: deforestation linked to Union consumption would rise to around 248 000 hectares per year by 2030 if nothing were done (Regulation 2023/1115).
Two deadlines, two data states
The application dates have been postponed twice, and the postponements moved more than the date. The original Article 38 named 30 December 2024 for everyone and 30 June 2025 for micro and small enterprises (Regulation 2023/1115). The first amendment moved both by a year to 30 December 2025 and 30 June 2026 (Regulation 2024/3234). The second amendment moved them by another year and also replaced the reference date for the size class: what counts now is who was established as a micro or small enterprise on 31 December 2024 (Regulation 2025/2650).
| Feature | Large and medium-sized operators | Micro and small enterprises |
|---|---|---|
| Application date | 30 December 2026 | 30 June 2027 |
| Reference date for classification | not relevant | established on 31 December 2024 |
| Due diligence statement | per consignment in the information system | per consignment, simplified for primary production |
| Geolocation | coordinates or polygon per plot | postal address allowed for micro primary producers |
| Registration | mandatory in the information system | mandatory as soon as SME status no longer applies |
| Retention | five years | five years |
In practice this means a company can be affected earlier for part of its range than for the rest, if suppliers of different size classes are involved. Micro or small primary producers may replace the geolocation with the postal address of the plots or of the holding (Regulation 2025/2650). A field that sometimes holds coordinates and sometimes an address needs two columns and a type marker in the data model - otherwise the import decides what it assumes is in there. How to model such ambiguities cleanly is covered in the article on data mapping between ERP and store.
The old dates are still in many documents
Which fields the article master has to carry
Article 9 paragraph 1 lists eight records that the operator collects, backs with evidence and keeps for five years (Regulation 2023/1115). Four of them are pure master data and can live on the article, four belong to the individual consignment and belong on the line. Without that split you either maintain the same batch several times or lose the link between delivery and evidence.
Description and species
Trade name, type of product and, for wood, the common name of the species as well as its full scientific name. Plus the list of relevant commodities contained.
Quantity in net mass
Kilograms of net mass and, where the Harmonised System code provides for a supplementary unit, that unit as well. Two quantity fields, not one with a conversion done in your head.
Country of production and region
The country of production and, where relevant, its subnational regions. Not the country of dispatch and not the country of the supplier - in existing data the two frequently diverge.
Geolocation
Latitude and longitude with at least six decimal digits, and a polygon for areas above four hectares. Plus the date or time range of production.
Upstream supplier and buyer
Name, address and email address of every business that supplied the goods and of every business, downstream operator or trader they were supplied to.
Evidence of lawfulness
Conclusive and verifiable information that the products are deforestation-free and that production complied with the legislation of the country of production.
Geolocation is the field where most legacy systems fail. What is required are latitude and longitude coordinates with at least six decimal digits; for plots above four hectares a polygon of enough coordinate pairs to describe the perimeter replaces the point (Regulation 2023/1115). A 40-character text field is not enough for that, and a single-precision floating point number loses the sixth decimal digit. The same care that batches and serial numbers between ERP and shop require applies here to coordinates.
article:
hs_code "4407 11" # decides whether the rules apply
species_scientific "Picea abies" # wood only
line:
quantity_net_mass 1250.000 kg # decimal type, no floating point
quantity_supp 2.400 m3 # only if the HS code provides for it
country_production "SE"
region "SE-AC"
geo_type point | polygon | address
geo_value "64.750123,20.950456" # 6 decimal digits
production_from 2025-05-01
production_to 2025-09-30
dds_reference "..." # reference number of the statement
dds_verification "..."
keep_until 2031-12-31 # date plus 5 years
The reference number is the connecting link
The operator submits the due diligence statement in the information system of the Commission and receives a reference number. That number is the thread the whole chain hangs on. It is communicated to downstream operators and traders, it is kept by them for five years, and it has to be available to the customs authorities before release for free circulation or export (Regulation 2023/1115). If it is missing from the customs declaration, the goods stand still. How the customs data itself travels through the systems is covered in the article on the EU customs reform 2026.
- Submit the statement: The operator transmits the due diligence statement before placing the product on the market or exporting it. The system issues a reference number and a verification number.
- Pass the number on: The reference numbers of the due diligence statements, or the identification numbers assigned, go to the downstream supply chain (Regulation 2025/2650). That is an obligation to deliver, not an answer given on request.
- Store the number: Downstream operators and traders record supplier, buyer and the reference number and keep that information for at least five years (Regulation 2025/2650).
- Report the number: Before release for free circulation, the person lodging the customs declaration makes the reference number available to the customs authorities (Regulation 2023/1115).
- Find the number again: During an inspection the number is read backwards - from the line through the delivery to the plot. Without a link in the data model that turns into a search through folders.
Keeping the number only in the free text of an order line means storing it formally and losing it in practice. It belongs in a field of its own with a format, a mandatory flag and a history, so that it reaches exports, documents and customs filings. The same reasoning applies to the process documentation of the interfaces: whatever is not documented has to be reconstructed during an audit.
One field, one format, one source
Why product passport and packaging data do not cover this
Many companies have built product data for two other sets of rules in recent years and hope it will serve the Deforestation Regulation as well. It does not add up. The digital product passport of the Ecodesign Regulation is connected through a data carrier to a persistent unique product identifier (Regulation ESPR 2024/1781); it describes the product, not the origin of a commodity on a particular plot. The manufacturer keeps the technical documentation for ten years (Regulation ESPR 2024/1781) - a different period from the five years of the Deforestation Regulation. Details of the structure are in the article on the digital product passport and ESPR product data.
The Packaging Regulation has applied since 12 August 2026 (Regulation PPWR 2025/40). From 12 February 2027, packaging covered by an extended producer responsibility scheme may be marked with a symbol in a QR code or another open digital marking technology (Regulation PPWR 2025/40). That code, too, describes material and disposal route, not the due diligence statement of the contents. Anyone who has already sorted out packaging data between ERP and shop knows the mechanics - but the fields are different ones.
- The product passport identifies a product, the due diligence statement a consignment. One field cannot be both.
- Packaging marking describes the wrapping, the Deforestation Regulation the contents and the land they grew on.
- The retention periods differ: ten years for technical documentation under the Ecodesign Regulation, five years for evidence and statements under the Deforestation Regulation.
- Only the Deforestation Regulation asks for coordinates. Neither the product passport nor the packaging marking carries a field for the geolocation of a plot.
The route through the systems
Technically the task is a data route with five stations. It starts at the supplier and ends at the customs declaration, and it runs in both directions: the records come in, the reference number goes out. A middleware between the systems is the calmer place for this than a point-to-point coupling, because the validation rules sit in one place instead of being repeated in every adapter. Where a legacy system brings no suitable interface, it is built as a dedicated programming interface.
Determine what is in scope
Use the Harmonised System code per article to check whether the product falls under the Annex. The result is stored as an attribute on the article, not derived anew for every transaction.
Collect supplier records
Request country of production, region, geolocation, production period and the evidence of lawfulness per batch. Receipt, format and completeness are logged.
Create the statement
The records are assembled into the due diligence statement and submitted in the information system. Reference number and verification number come back and are stored on the batch.
Distribute the number
The reference number travels to delivery note, invoice, customs declaration and to the downstream buyers. Every recipient gets it as a field, not as text in a remark.
Keep the evidence
All records and supporting documents stay retrievable for five years from placing on the market, linked to line, batch and statement. One export per transaction is enough, a folder full of PDF files is not.
Use the Harmonised System code per article to check whether the product falls under the Annex. The result is stored as an attribute on the article, not derived anew for every transaction.
Request country of production, region, geolocation, production period and the evidence of lawfulness per batch. Receipt, format and completeness are logged.
The records are assembled into the due diligence statement and submitted in the information system. Reference number and verification number come back and are stored on the batch.
The reference number travels to delivery note, invoice, customs declaration and to the downstream buyers. Every recipient gets it as a field, not as text in a remark.
All records and supporting documents stay retrievable for five years from placing on the market, linked to line, batch and statement. One export per transaction is enough, a folder full of PDF files is not.
Little of this remains visible in the shop, and that is intentional. Customers see no new field, at most a note that a line is currently not orderable because the statement is missing. That block belongs in the same place as other availability rules - how it interacts with product variants from the ERP is decided by the data model of the variant, not by the front end.
Checks, fines and an outage of the information system
The density of checks is quantified in the regulation. Competent authorities check at least 3 per cent of operators, downstream non-SME operators and non-SME traders each year; for commodities from high-risk countries the rate rises to at least 9 per cent of businesses and 9 per cent of the quantity (Regulation 2025/2650). These figures are minimum values, not target values, and they refer to the territory of the individual member state.
The sanctions framework is defined from below: for legal persons the maximum amount of the fine is set at at least 4 per cent of annual Union-wide turnover (Regulation 2025/2650). That is a floor for the range member states have to provide, not the fine to be expected. For project planning the figure is useful all the same, because it marks the order of magnitude in which decisions about data quality are taken.
When the information system is unavailable
What to do in the project now
There are roughly fifteen months left until the application date, and the effort does not sit in the connection to the information system but before it: in the question of which system carries which field. That is exactly the question master data management answers. Leave it open and you build the interface twice. What such an undertaking looks like in scope is shown by the overview of services.
- Match the range against the Annex of the regulation and store the result as an attribute on the article, including the reasoning.
- Maintain HS codes completely. Without them scope can neither be determined nor evidenced later.
- Create the field list from Article 9 paragraph 1 in the ERP: eight records, split between article and line level.
- Provide two columns for the geolocation - type and value - so that point, polygon and postal address stay distinguishable.
- Carry the reference number as a field of its own with format and history and pass it through to delivery note, invoice and customs declaration.
- Implement retention technically: five years from placing on the market, linked to line and batch, retrievable without manual work.
- Prepare supplier communication. The records rarely arrive on their own and rarely in the format you want.
- Add a fallback for an outage of the information system to the operating concept, including responsibility and the reporting route.
A due diligence statement without the reference number in the line record is a promise without evidence. Only the link between number, delivery and plot turns it into an answer that survives an inspection.
Sources and Studies