EUDR Transition Periods and Stocks: Your Questions Answered

Editor's note: This article has been updated to reflect the current regulatory position as of August 2026, including the confirmed 12-month delay to EUDR enforcement, the Delegated Act adopted in July 2026, and Commission FAQ Version 5 (April 2026). 

As part of our ongoing EUDR Lunchtime Series, our Head of Market Development, Anna Roberts, hosted a dedicated session on transition periods and stocks under the EU Deforestation Regulation (EUDR).

The session attracted many thoughtful and practical questions from participants. We've compiled them below, alongside our responses, so others preparing for compliance can benefit from the discussion.

⚠️ Please note: these answers reflect our current understanding as of August 2026 and have been updated since the webinar was held in September 2025. Guidance and enforcement practices continue to evolve, and we recommend monitoring updates from the European Commission and relevant industry associations.

Helpful resources:

• Implementation Act
• Official Guidance Document
• EUDR April FAQs
• Annex 1
• EUDR scenarios

Questions relating to product transformation

1. If I am an SME and I am buying material with HS code 4809 and I make available on the EU market my product which is 4811. Do I need to create a new DDS even though the first two digits are the same (48XX), or can I forward the reference numbers I have received from my supplier for the 4809 material?

SME downstream operators are not required to exercise due diligence for relevant products contained in or made from relevant products that have already been subject to due diligence and for which a Due Diligence Statement (DDS) has already been submitted.

If your product (HS 4811) is made entirely from material (HS 4809) that was already subject to due diligence by your supplier, meaning all product inputs are covered by an upstream DDS, you are exempt from exercising due diligence and submitting a new DDS.

If however you purchase 4809 from non-EU suppliers and there are no upstream DDS, you would be obligated to conduct full due diligence and submit a DDS for the inbound products. You can then reference the inbound DDS when you sell to your EU customers.

Questions relating to wood-based products and EUTR

2. So for timber, EUDR only applies when it is either: (1) harvested before 29 June 2023 and brought on the market from 30 December 2026; (2) harvested between 29 June 2023 and 30 December 2025 and brought on the market from 30 December 2026; or (3) harvested after 30 December 2025. How do we identify this to customers and do some products get a TRACES DDS and others not?

This is correct. Following the confirmed 12-month delay to EUDR enforcement, the application date is now 30 December 2026 for large and medium operators, and 30 June 2027 for SMEs.

When you place a mixed batch on the market, a DDS is only required for the portion of stock subject to EUDR. EUTR products do not require a DDS. For stock placed on the EU market before 29 June 2023, you can use exemption code Y132 on customer documents.

While the regulations do not explicitly require the physical separation of EUTR and EUDR stock, you must be able to prove which items fall under which category. This makes a reliable traceability system essential.

Your customer or the competent authority may ask you for evidence that goods were placed on the market before or during the transition period. This can take the form of bills of lading, customs declarations, dispatch notes, and similar documentation.

As only products subject to EUDR will carry a DDS and associated reference number (or declaration identifier), your invoices or delivery notes will need to distinguish between the two types of stock, indicating which part of an order is covered by EUTR and which by EUDR, along with the corresponding DDS reference numbers. Some of our customers are approaching this in a similar way to how they currently detail certification status on product descriptions (e.g. 70% PEFC; FSC Mix).

3. For medium and large sized companies: if we ship paper made from Korean pulp, arriving in France on 12 December 2026 and placed on the market on that date, does it need to comply with EUDR if the goods are sold to clients in January 2027?

No. The product does not need to comply with EUDR. It was placed on the EU market on 12 December 2026, during the transitional period and before the EUDR application date of 30 December 2026. It does need to comply with the EUTR however.

When the product is subsequently sold to clients in January 2027 (which counts as an act of 'making available'), you won’t have a DDS reference number to share with them, but your customer may ask for you to share evidence that the product was placed on the market during the transitional period. A customs declaration would serve as proof, as confirmed in Question 9.2 of the official FAQ.

4. If I understand correctly, for a finished good concerned by the EUTR and imported between 2023 and 2026, we need to have an EUDR DDS if we sell the product in 2027. Is that correct?

No. You do not need to submit an EUDR DDS for that product. A product already imported into the EU and placed on the market before 30 December 2026 falls within the transitional period. It needs to comply with EUTR but not EUDR.

When you sell the product, you are 'making it available on the market'. For products placed on the market during the transitional period, FAQ 9.1 explains that the obligation for downstream actors is limited to: "...gathering adequately conclusive and verifiable evidence to prove that the relevant commodity used to produce such relevant product was placed on the EU market before the entry into application of the Regulation."

5. Just to be clear about EUTR products harvested after 29 June 2025 and imported into the EU before 30 December 2026: do you need a DDS (1) always at sales after 30 December 2026, or (2) only when products are processed after 30 December 2026?

The two critical factors are when the product was harvested, and when it was 'placed on the market'. For imports, this is the date it is released for free circulation in the EU.

If the product was harvested after 29 June 2025 but placed on the market before the EUDR application date of 30 December 2026, EUTR applies. EUDR would only apply, and a DDS would only be required, if the product is placed on the market on or after 30 December 2026.

Your only obligation relating to EUDR in this scenario is to be able to provide verifiable proof, such as a customs declaration, that the product was placed on the market before 30 December 2026.

Questions relating to the obligations of non-EU businesses

6. We are a book publisher in the UK, selling books directly to EU consumers through our website and Kickstarter campaigns, fulfilled from a UK warehouse. Some of our products are out of scope of EUDR by way of HS/CN code 4901, but others (such as plain notebooks) are still in scope with HS/CN code 4820. Can we continue selling stock of the plain notebooks produced during the transition period?

You can continue selling stock to EU customers during the transitional period without having to comply with EUDR. After the transitional period ends on 30 December 2026, there are four key considerations:

1. The exemption for 'personal use' does not apply to you as a commercial seller. It applies to your customers purchasing books for personal or private consumption.
2. If your stock comes from in-scope raw materials already placed on the EU market (i.e., from EU forests, pulp mills or paper mills), you do not need to comply with EUDR and can use either: (a) exemption code Y132 for stock placed on the EU market prior to 29 June 2023, or (b) a 'conventional DDS code' issued by the European Commission for stock already placed on the EU market during the transition period.
3. If your stock comes from in-scope raw materials not already placed on the EU market (i.e., from non-EU suppliers), you can continue selling to EU customers provided you supply them with the information they need to perform their own due diligence, including geolocations. Without this, your customers may be unable to comply with EUDR and may be unlikely to purchase the stock.
4. For scenarios (a) and (b), your customers will need to confirm that products were placed on the market before or during the transition period. Evidence such as customs declarations and bills of lading will be required (refer to FAQ 9.2).

7. We are a publisher with UK export copies of books already in the EU market. We're told that any new imports still count as 'first placed' even though it is the same book and batch. If a book is already in Germany and Spain, why would sending copies to Italy count as 'first placed'?

Following the removal of printed materials with HS/CN codes starting ‘49’ from the scope of EUDR, this question is no longer relevant. It may still be interesting to the reader to understand what the meaning of ‘placed on the EU market’ is. 

The advice you have received is correct. The concept of 'placing on the market' under the EUDR applies to each individual physical product, not to a product line or batch. It is defined by Article 2(16) as "first making available of a relevant commodity or relevant product on the Union market."

The Commission's Guidance Document clarifies in section 1.3(a): "The concept of 'placing on the market' refers to each individual relevant commodity or product, not to a type of product, irrespective of whether it was manufactured as an individual unit or a series."

This means that while some copies of your book are already on the EU market in Germany and Spain, any additional copies held in your UK warehouse have not yet been placed on the EU market. When you import a copy from UK stock into Italy, that specific book is being placed on the Union market for the first time, triggering EUDR obligations for that individual product.

One area to clarify: are the books already in the EU market held in a warehouse and yet to be sold, or are they with customers? If they are in a warehouse and have not yet been subject to a commercial transaction, EUDR would apply when they are sold on or after 30 December 2026.

8. We are a consumer goods company in the UK. If we sold an EUDR-applicable item into Europe in 2024, would we be able to prove 'placing on the market' in 2027 through customs declarations?

Yes. A customs declaration is considered valid proof that a product was placed on the EU market.

The EUDR's main obligations apply from 30 December 2026. Any product placed on the market before this date falls within the transitional period and is exempt from the full due diligence requirements. A sale in 2024 is well within this period.

Under Question 9.2 of the official FAQ: "In case of imported products, the customs declaration of the relevant commodities or relevant products in question will be accepted as evidence of having been placed on the EU market before the date of application." Your 2024 customs declarations will therefore be accepted as proof in 2027 and beyond.

9. We import finished chocolate products (HS1806) from EU-based suppliers into Great Britain, covered by a DDS reference number submitted by the EU exporter. Are we considered a Trader under the EUDR?

No. As a UK importer purchasing from EU suppliers, you are not considered a trader or operator under the EUDR and have no obligations under the Regulation.

The exception is if you are based in Northern Ireland, which under the Windsor Framework is considered to be in the EU for EUDR purposes, in which case you would be a downstream trader.

If you subsequently export products back to EU customers who re-import them, it will be commercially beneficial to provide either the upstream DDS reference and verification numbers from your suppliers, or (more likely) evidence of the goods having previously been placed on the EU market, to facilitate their compliance.

10. We import finished chocolate products (HS1806) from outside the EU into Great Britain. The product is not being placed on the EU market. If this chocolate is later distributed to Northern Ireland, are we required to submit a DDS?

Yes. Under the Windsor Framework, Northern Ireland is considered to be within the EU for the purposes of EUDR.

HS code 1806 is directly in scope of the EUDR. If the product is distributed to Northern Ireland for commercial purposes, the organisation placing it on the EU market will be required to submit a DDS and exercise full due diligence, since the product and its raw material inputs have not previously been placed on the EU market.

The company placing the finished product on the market will need to demonstrate that it has assessed the full supply chain, conducted due diligence back to source (including submitting geolocations), and where the place of harvest is deemed standard risk, carried out risk assessment and mitigation.

In this scenario, it will be important to determine whether your business or your customer would be classed as the first operator.

Questions relating to company size

11. We are an SME but our clients are not. Do we have to do anything specific?

This depends on whether you are the first company placing the products on the EU market (upstream operator) or a downstream operator purchasing from EU suppliers.

There is no minimum threshold for EUDR obligations based on company size alone. As an SME you have specific obligations, but these are simplified compared to non-SMEs. The key action is to pass on the required compliance information, including DDS reference numbers, to your non-SME clients.

Your exact obligations depend on your role in the supply chain:

• SME upstream operator or trader (first to place the product on the EU market, e.g. as an importer): You have the full due diligence obligations of any operator regardless of size. You must exercise due diligence, submit a DDS to the TRACES NT system, and provide the DDS reference number to your non-SME client.
• SME downstream operator (processing a product already covered by a DDS into a new EUDR-relevant product): You are exempt from exercising due diligence and submitting a new DDS. Your key obligation is to pass the DDS reference number from your supplier to your non-SME client.
• SME downstream trader (buying and selling a product already placed on the market): You are exempt from exercising due diligence and submitting a DDS. Your obligations are to keep records of your suppliers and the DDS reference numbers of the products you handle.

The other difference between SME and non-SME obligations is that non-SMEs must register as a business in TRACES even when they are First Downstream or Subsequent Downstream Operators or Traders. SMEs do not need to do this. 

Questions about other topics

12. For samples from outside the EU with no commercial value, what is the process?

Following the Delegated Act adopted by the European Commission in July 2026, samples are now exempt from EUDR requirements under certain conditions. The exemption applies to samples that are of negligible value and quantity and can only be consumed or used to solicit orders for goods of the type they represent, provided the manner of presentation and quantity rule out consumption or use for any other purpose.

A similar exemption applies to brochures.

If you are unsure whether your samples meet the conditions set out in the Delegated Act, we recommend seeking independent advice or getting in touch with our team.

Conclusion

The EUDR's transition periods raise complex questions, particularly around stock already in circulation and the interplay between EUTR and EUDR obligations. With the application date now confirmed as 30 December 2026 for large and medium operators, and 30 June 2027 for SMEs, businesses have additional time to prepare. The complexity of the regulation remains unchanged however, and enforcement is already underway in some member states.

At Interu, we're helping businesses build the traceability and reporting infrastructure they need to stay compliant, reduce risk, and maintain market access. Get in touch with our team to explore how we can support your EUDR compliance journey.

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.

‍