The EU Deforestation Regulation (EUDR) is about to enter its implementation phase.

Cross-border sellers of wooden furniture, wooden kitchenware, paper and related products should promptly check product scope, raw material sources and supply chain documentation.

For sellers operating on Amazon’s European marketplaces, EUDR not only affects EU import customs clearance, but also involves compliance requirements under Invoicing by Amazon (IBA). Reviewing products in advance is safer than supplementing information near the deadline.

1. Who needs to comply with EUDR?

EUDR, short for the EU Deforestation Regulation, aims to reduce the EU market’s impact on deforestation and forest degradation.

Simply put, relevant goods entering the EU market must not only comply with relevant legal requirements in the producing country, but also meet deforestation-free requirements and complete due diligence as required.

EUDR mainly covers seven relevant commodities: cattle, cocoa, coffee, palm oil, rubber, soy and wood, as well as certain derived products listed in the annex to the regulation.

In addition to product scope, you also need to determine your role in the supply chain.

If a seller places relevant products on the EU market for the first time, it may be an upstream operator and must fulfill due diligence obligations. If due diligence has already been completed for the goods, the seller may be a downstream operator or trader with different obligations.

Special note: Chinese sellers may also become upstream operators due to actual import and market placement activities. Do not assume EUDR does not apply simply because your company is registered in China.

2. Large and medium-sized vs. micro and small operators

According to the current timeline published by the European Commission, EUDR will apply in phases. Sellers need to confirm their specific dates based on company size and product category.

Large and medium-sized operators: December 30, 2026

In principle, EUDR requirements apply from that date.

Micro and small operators: June 30, 2027

Most eligible micro and small operators can apply the deferred date.

Micro and small operators already covered by the EU Timber Regulation (EUTR): December 30, 2026

For example, some wooden furniture, wooden kitchenware and paper product businesses cannot simply rely on micro/small enterprise status for deferred application.

3. What do Amazon sellers need to submit?

For products subject to EUDR, sellers need to first confirm their responsibilities, then prepare the corresponding due diligence information.

1. Basic product and supply chain information

Including product name, product type, quantity, relevant raw material information, producing country, supplier information, and documents proving that the product complies with local production laws.

2. Raw material production location information

One key EUDR requirement is to trace the geographic location of the production plots for relevant raw materials. For cattle-related products, geographic information on the places where cattle were raised may also be required.

Therefore, a supplier business license, purchase invoice or an ordinary certificate of origin alone may not be enough to meet all requirements. Sellers should confirm in advance with upstream suppliers whether complete and verifiable information can be provided.

3. Due Diligence Statement (DDS) and reference number

If a seller is an upstream operator required to fulfill due diligence obligations, the following steps are usually required:

① Collect product and raw material source information.

② Conduct a risk assessment and take risk mitigation measures if necessary.

③ Submit a Due Diligence Statement (DDS) through the EU’s EUDR information system. Eligible micro and small primary operators may use a simplified statement.

④ Submit the DDS reference number or applicable simplified statement identifier to Amazon as required.

4. Submit required information in Seller Central

For sellers enrolled in Invoicing by Amazon, check the Account Health and Product Compliance pages in Seller Central, and watch for EUDR-specific notices from Amazon.

You can access “Submit compliance information” from the Product Policy Compliance page in Seller Central, select EUDR-related options, and create, link and submit due diligence information as instructed.

4. How does EUDR affect Amazon sellers?

1. Failure to submit information may lead to loss of IBA eligibility

For relevant products that need EUDR compliance information, Amazon requires sellers to provide the applicable DDS reference number and verification number, or submit proof of an applicable exemption.

If valid information is not submitted as required by the platform, the relevant products may be removed from the IBA program.

Note that leaving IBA does not mean leaving EUDR regulation. Sellers still need to determine, based on product scope and their own role, whether they are legally required to fulfill due diligence and other compliance obligations.

2. Even if products are outside EUDR scope, submit exemption information correctly

If a product is made of pure metal, plastic, textiles, etc., and is verified to be outside the scope of EUDR, sellers should submit the applicable product-level exemption information according to the options provided by Amazon.

Amazon’s DDI (Due Diligence Information) records allow you to enter a reason for exemption. Products eligible for exemption may still need a DDI record, but you do not need to directly submit a DDS number or raw material records for them.

3. Even for the same ASIN, pay attention to raw material sources across batches

Amazon notes that if the same product uses raw materials from different locations, the relevant due diligence information may differ. When the supply chain, raw material source location or exemption status changes, sellers may need to create a new DDI record.

Therefore, sellers cannot assume that all inventory, batches and import activities can share the same set of information just because they share the same ASIN.

Final note:

For sellers of wooden furniture, wooden kitchenware, paper products and other related products, it is advisable to conduct compliance checks as early as possible to avoid future sales disruptions caused by insufficient documentation.

This concludes the content shared by Yiju Overseas. Feel free to leave a comment and discuss below!