马士基提示欧盟反森林砍伐法规EUDR于2026年12月30日适用

We would like to inform customers that the EU Deforestation Regulation (EUDR) enters into application on 30 December 2026 for large and medium operators and traders, and on 30 June 2027 for micro and small enterprises established as such by 31 December 2024.

Following two postponements, the European Commission has confirmed that no further delay will be granted. The below guide is to give Maersk customers as much information as possible on EUDR so they stay compliant at the border. Maersk experts remain on hand to support, so please don’t hesitate to reach out.

Application timeline

From the application date, goods within scope may only be placed on, or exported from, the EU market where they are deforestation-free, produced in accordance with the legislation of the country of production, and covered by a Due Diligence Statement (DDS). Customs declarations for EUDR goods that do not contain a valid DDS reference number will not be accepted.

Under EUDR, the operator is the company that first places a relevant product on the EU market or exports it from the EU. The operator is the party responsible for completing the required due diligence and submitting the Due Diligence Statement (DDS), where required. The operator is not necessarily the shipper, consignee, importer of record or the party arranging the transport or customs clearance. Customers should therefore establish which entity in their supply chain is the responsible operator for each relevant product and trade flow.

The deforestation cut-off date remains 31 December 2020: in-scope commodities must originate from land not deforested or degraded after that date.

Commodities and products in scope

The seven core commodities are cattle, cocoa, coffee, oil palm, rubber, soya, and wood, together with a wide range of derived products listed in Annex I to Regulation (EU) 2023/1115.

The scope was updated in September 2026 (Commission Delegated Regulation (EU) 2026/2102) and amends Annex I as follows:

• Added (applicable from 30 December 2027): soluble coffee, certain palm oil derivatives used in oleochemicals, and frozen cattle tongues.
• Exempted: waste, used and second-hand products, packaging material, marketing and information materials, items of correspondence, products used in the manufacture of medicinal products, and samples for analysis, examination and testing.

We recommend a fresh classification review against the amended Annex I — product scope has moved twice in 2026, and your 2025 assessment may no longer be accurate. Please note that the EUR-Lex consolidated text of Regulation (EU) 2023/1115 will not reflect Regulation (EU) 2026/2102 until it is re-consolidated; both texts should be read together.

Simplifications you should be aware of

Regulation (EU) 2025/2650 and the May 2026 simplification package materially reduced the administrative burden, but did not remove the core obligations:

• One filer, not every link: Only the operator who first places the product on the EU market (or exports it) submits a full DDS. Downstream operators retain and pass on the DDS reference number rather than repeating due diligence.
• Annual rather than per-shipment: A DDS may be submitted annually per product instead of per consignment – but you must actively monitor and re-run due diligence when suppliers, geolocations, or harvest dates change.
• Simplified declaration for the smallest operators: Micro and small primary operators file a one-off simplified declaration and may use postal addresses instead of geolocation coordinates.
• Information System: The EUDR Information System (TRACES) reopened in June 2026, with grouping of DDS reference numbers under a single identifier, API submission, and contingency arrangements to be in place by 30 December 2026.

What you need to do now

• Map your trade flows. Identify which of your products are in scope under the amended Annex I, and where you are – and are not – the responsible operator.
• Engage your suppliers. Collect supplier, plot geolocation and harvest-date data, including upstream tiers (for example, the timber supplier behind your furniture supplier). This is the single longest lead-time activity.
• Run the risk assessment and mitigation. Assess and, where necessary, mitigate risk until it is negligible before submitting.
• Submit your Due Diligence Statement. File the above information into TRACES and retain the reference number. Maersk can support with filing information into TRACES and retrieving the needed DDS reference.
• Provide the reference to your broker contact at Maersk. The DDS reference number must be quoted on the customs declaration. Please provide it to Maersk in advance of arrival – not at the border.
• Register early. Ensure your EU entity has access to the EUDR Information System and that user rights are assigned well before December.

Risk of inaction

Where a DDS reference is not available at the time of declaration, the declaration cannot be validated and goods will not be released. This can result in additional costs such as demurrage and detention, in addition to penalties under national enforcement regimes of up to 4% of EU annual turnover, confiscation of goods and revenues, and exclusion from public procurement.

Please note: the obligation to complete due diligence and submit the DDS rests with the operator placing the goods on the market. Maersk cannot submit a declaration for EUDR goods without a valid DDS reference and cannot accept liability for storage or demurrage costs arising where the required due diligence has not been completed.

We are here to help

Maersk offers modular EUDR support covering readiness and advisory, managed due diligence, customs integration and ongoing monitoring, allowing you to choose the level of support that best fits your needs.

We will continue to keep customers informed of the latest developments as soon as they become available, and when the EU Commission publishes further guidance.

To discuss your EUDR readiness or to request support, please contact your local Maersk representative or your usual Maersk contact.