How the report is built
Method and legal basis stated as at 9 July 2026
Your report is a structured reading of your answers against the EU Deforestation Regulation. Every determination traces to a specific part of the regulation or its implementing texts, and the report is dated so you know exactly what version of a moving rulebook it reflects. Here is precisely how each part is worked out.
1. Scope — products against the seven commodities and Annex I
The regulation covers seven relevant commodities — cattle, cocoa, coffee, oil palm, rubber, soya and wood — and the products derived from them that are listed by HS code in Annex I of Regulation (EU) 2023/1115. We screen each product you enter, in plain language or by HS code, against that commodity list and the Annex I code ranges (for example coffee under HS 0901, cocoa and chocolate under 1801–1806, wood and wooden furniture across chapters 44 and 9403, natural rubber and articles under 4001 and 4011–4017).
A product that maps to a listed commodity and an Annex I code is flagged in scope. A product that maps to neither — cotton, for instance, which is not a listed commodity — is flagged out of scope. Where a product sits in a category the Commission has proposed to change, it is flagged in scope, under revision rather than presented as settled.
2. Role — do you file a Due Diligence Statement, or collect one?
The regulation distinguishes operators (who place a product on, or export it from, the EU market for the first time) from traders and downstream operators further along the chain. Your role decides your duty. From your answers — how the goods reach the EU, whether they are placed under your own name or brand, and your company size — the report determines whether you are the first operator who must exercise due diligence and file a Due Diligence Statement (DDS), or a downstream operator or trader who instead collects and passes on the upstream DDS reference numbers. This role logic reflects the position after the December 2025 amendment (Regulation (EU) 2025/2650), which changed the obligations for downstream operators.
3. Deadline — which of the two dates applies to you
The regulation applies in two waves. Large and medium operators and traders are bound from 30 December 2026; micro and small operators get until 30 June 2027 — except that small operators handling timber and wood products remain on the December 2026 date. The report sets your deadline from your declared company size and whether your product mix includes wood.
4. Country risk — low, standard or high
Each producing country is assigned a risk tier under the country benchmarking system — low, standard or high — implemented by Implementing Regulation (EU) 2025/1093, which sets the initial classification list. Low-risk origin permits simplified due diligence; high-risk origin brings enhanced scrutiny. Mixed or unclear origin pulls the assessment up to the stricter tier. The report maps your declared origin countries to their tier and explains what the tier changes in practice.
What the report never does: verify deforestation-free status. Every determination above concerns your obligations — scope, role, deadline, documentary duties. The report does not, and cannot, confirm that your goods came from land not deforested or degraded after 31 December 2020. That proof rests on your supplier evidence, plot geolocation and satellite screening. We tell you what the duty is and who owns it; discharging it is separate work.
Legal basis and "as of" dating
- Regulation (EU) 2023/1115 — the EU Deforestation Regulation itself (scope, definitions, Annex I, operator and trader duties, due diligence).
- Regulation (EU) 2025/2650 — the December 2025 amendment (deadlines and downstream-operator obligations).
- Implementing Regulation (EU) 2025/1093 — the country benchmarking classification (low / standard / high risk).
- European Commission EUDR guidance — the Commission's guidance documents and FAQ, used to read the operative texts.
Every report carries the date on which its position was determined. That matters here because the rulebook is still moving.
What is still moving — and how we handle it
Two pending changes could shift a determination after your report is issued, so we flag them rather than hide them:
- A delegated act on product scope is pending — proposals under discussion include removing some products (for example leather and retreaded tyres) and adding others (such as soluble coffee and certain palm derivatives). Anything caught by a proposed change is flagged in your report as under revision.
- A country-benchmarking review is due in 2026, which can move a country between risk tiers and change the level of due diligence required for that origin.
Because of this, the report is a dated screening, not a permanent ruling. Re-check your position against the current texts before you rely on it for a market-access decision, and confirm with counsel.
Questions about the method? Email hello@eudrscope.com. See also our Sources.