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Following our recent webinar with the Department for Business and Trade’s UK Export Academy, we’re running a series of blogs unpacking the key themes and questions raised during the session - from scope and applicability, to due diligence processes, TRACES submissions, and supplier data management.
In this instalment, we focus on what the regulation means specifically for UK and Northern Irish businesses.
Please note: this guidance is based on our understanding as of 29th October 2025 and doesn’t take into consideration the European Commission’s recent proposal. If this is confirmed, we will update this piece with the new guidance.
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Does EUDR apply to UK businesses, or only to EU importers?
The EUDR applies to EU importers, manufacturers and exporters. UK businesses are not legally obliged to conform with EUDR, though it may be in commercial interests to do so. The exception is Northern Ireland (see below).
How does it apply to Northern Ireland businesses under the Windsor Framework?
As of October 2025, Northern Irish businesses must comply with EUDR. This means they have the same obligations as EU businesses handling in-scope products. We are monitoring this closely in case there are any changes.
Can NI-based businesses submit Due Diligence Statements (DDS) in TRACES?
Yes. NI-based businesses, like EU ones, can submit a DDS in TRACES.
Will UK companies be able to create or submit a DDS using a NI (XI) EORI number?
Yes, UK companies will need to create an account on TRACES NT, referencing their NI (XI) EORI number when doing so.
How does EUDR apply when UK exporters sell to EU customers through a Northern Irish intermediary or subsidiary?
It depends on a few things, and there are legal as well as practical considerations.
The concept of ‘first placing on the market’ is critical. It is the organisation first placing the goods on the EU market who is responsible for compliance. First placing on the market implies the goods are physically in the EU, and that they are there in a commercial context (i.e., not for private / personal consumption).
Often it is the EU customer who first places the goods on the market, but depending on International Commercial Terms, and who is responsible for clearing customs, it might be the NI intermediary or subsidiary. Per Q2 above, Northern Irish businesses are in scope of EUDR.
This is different to Q4, when a UK business uses a Northern Irish EORI number to submit DDS in TRACES. In this scenario, the EU customer still needs to submit a DDS themselves and would be considered the first EU operator placing the goods on the EU market (since the UK business constitutes a non-EU company placing the goods on the market).
In summary:
UK businesses aren’t legally required to comply with EUDR, but many will choose to align to keep trading smoothly with EU customers. Under the Windsor Framework, Northern Irish businesses must comply fully from December 31st 2025, with the same obligations as EU operators. The key factor is who first places the goods on the EU market - that’s where responsibility for compliance lies.
What’s Next
This Q&A is part of our Top Questions from the UK Export Academy EUDR Webinar series, where we’ll continue breaking down the issues most important to businesses preparing for EUDR. If you’d like to see the full recording, you can do so here.
Next up, we turn our attention to products and materials - one of the most common areas of confusion for exporters and importers alike.
Stay tuned, or reach out to our team to learn how Interu can help you prepare for compliance while maintaining market access and transparency across your supply chain.
Disclaimer:
We provide a portal for the transfer of data from third party sources to individual users. You are responsible for ensuring that your use of the portal, including the data, is sufficient or appropriate for any particular use or circumstances, including taking independent professional advice as necessary. For the avoidance of doubt, you should always seek independent professional advice to confirm your compliance with applicable law.
