EU Deforestation 2026: New Obligations for Importers and Traders

Key data

If your company imports, exports or trades in the EU products from agriculture, food, timber, leather or rubber, this regulation may change what you need to document to continue operating. Delegated Regulation (EU) 2026/2102, published on 17 September 2026, amends Regulation (EU) 2023/1115—the European regulation on deforestation-free products—expanding the catalogue of raw materials and products subject to its due diligence obligations.

The immediate question for any executive or procurement manager is straightforward: are my products now on the list? If the answer is yes, the clock is already ticking.

What does this regulation establish?

Regulation (EU) 2023/1115 already required certain companies to demonstrate that certain products did not come from deforested or degraded land after 31 December 2020. The new Delegated Regulation (EU) 2026/2102 extends that same regime to a broader list of raw materials and products.

The specific obligations that apply to products incorporated into the expanded list are:

• Geolocation of plots: documenting the coordinates of the land of origin of the raw materials.
• Due diligence declarations: preparing and submitting declarations that certify that the product does not come from deforested or degraded land after 31 December 2020.
• Supply chain audits: verifying and documenting the complete traceability of the product from origin to marketing in the EU.

The following table summarises the regulatory change between the original standard and the amendment:

Economic and operational impact

The impact is not just documentary: it has real operational costs. Companies that fall within the new scope will need to invest in:

• Traceability systems: tools to collect and manage plot coordinates and origin documentation.
• Supplier audits: review and verification of the supply chain, especially when the origin is outside the EU.
• Legal and compliance resources: preparation of due diligence declarations and management of compliance risk.
• Possible supplier changes: if a current supplier cannot prove deforestation-free origin, the company will need to find alternatives or assume the risk of not being able to market the product.

The cost of non-compliance is even higher: the regulation provides for significant penalties and prohibition of marketing in the European market, which can mean the direct loss of entire business lines.

Who does it affect?

The regulation directly affects companies operating in the EU with raw materials or products linked to deforestation. The sectors with the greatest exposure are:

• Agriculture: importers and traders of agricultural raw materials that may be linked to land use change.
• Food: companies working with ingredients or raw materials of plant origin from areas at risk of deforestation.
• Timber and derivatives: importers, manufacturers and distributors of timber or cellulose products.
• Leather: companies in the fashion, footwear or leather goods sector that import leather from third countries.
• Rubber: manufacturers and importers of products incorporating natural rubber.
• Logistics operators and traders: intermediaries that market in the EU any of the products included in the expanded list.

The determining criterion is whether your company's products are incorporated into the expanded list by Delegated Regulation (EU) 2026/2102. Urgent review of that catalogue is the first mandatory step.

Practical example

Imagine a Spanish company that imports leather from Brazil to manufacture footwear. Until now, if the leather was not on the original list of Regulation (EU) 2023/1115, it had no anti-deforestation due diligence obligations. If Delegated Regulation (EU) 2026/2102 incorporates that product into the expanded list, the company will need to:

1. Request from its Brazilian supplier the geolocation coordinates of the plots where the cattle were raised.
2. Verify that those plots were not subject to deforestation or forest degradation after 31 December 2020.
3. Prepare and register a due diligence declaration before marketing the product in the EU.
4. If the supplier cannot provide that documentation, the company will need to change suppliers or assume that it cannot import that leather to the European market.

The same scheme applies to an importer of Indonesian timber, a palm oil trader or a food company using cocoa of tropical origin.

What should companies do now?

1. Review the expanded list: consult the full text of Delegated Regulation (EU) 2026/2102 to verify whether any of your products or raw materials are incorporated into the new scope.
2. Audit the supply chain: identify all suppliers of potentially affected raw materials and assess their ability to provide origin documentation and plot geolocation.
3. Implement traceability systems: establish internal processes to collect, manage and retain the due diligence documentation required by the regulation.
4. Prepare due diligence declarations: prepare the necessary declaration models for each affected product before its marketing in the EU.
5. Plan supplier alternatives: if any current supplier cannot prove deforestation-free origin after 31 December 2020, begin searching for alternatives with sufficient advance notice.
6. Seek specialist advice: given that non-compliance can result in significant penalties and prohibition of marketing, it is advisable to have legal or regulatory compliance support to validate the processes implemented.

Official source

Consult full regulation at official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202602102