Lao Zhou works out of Lanshan District in Linyi and has been exporting plywood for seventeen years. He ships more than two hundred containers to Europe a year. The customs broker knows him, the freight forwarder knows him, the inspector knows him. In October 2025 a Dutch client of nine years sent an email with a four-word subject line: EUDR Data Request. Twelve pages, thirty-seven fields. The first one asked for the harvest plot coordinates of every single tree.
Seven commodities, and the HS codes behind them
EUDR is short for the EU Deforestation Regulation (EU) 2023/1115. It entered into force on 29 June 2023 and covers seven commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood.
Whether your goods are in scope is decided by HS code, not by how you describe your own industry. Wood is by far the widest bucket: essentially all of Chapter 44, from 4401 fuel wood through to 4421 other articles of wood; pulp 4701 to 4704; parts of 4801 to 4811 plus 4813 to 4822 for paper and paperboard; printed matter 4901; wooden furniture 9403.30, 9403.40, 9403.60 and 9403.91; prefabricated buildings 9406.10.
Rubber means 4001 natural rubber plus parts of 4005 to 4017, with tyres under 4011. Palm oil 1511 and 1513, fatty acids 3823, glycerol 2905.45. Soya 1201, 1208, 1507 and 2304. Beef 0102, 0201, 0202, 0206 and 1602. Cocoa 1801 to 1806, coffee 0901.
The simplification package of May 2026 touched the scope list again: soluble coffee (2101) and certain palm oil derivatives were proposed for inclusion, while leather, retreaded tyres, product samples, some packaging, used goods and waste were proposed for exclusion. A draft is a draft. Before you ship, run the product through the Commission online scope checker, or simply ask the buyer for the CN code. There is a small trap hidden here as well: you declare under China ten-digit codes, the buyer files the DDS under the eight-digit EU CN code. 4412 33 and 4412.33.00 are not the same thing in that system.
A DDS is not a form, it is a data chain
DDS stands for Due Diligence Statement. The legal duty to file it sits with the EU importer. A Chinese exporter is not an EUDR operator unless it has an entity inside the EU that places goods on the market or exports from it. The obligation belongs to your buyer, but the data is entirely in your hands. That is why those thirty-seven fields land in your inbox.
One DDS covers one consignment. It has to carry the product description and CN code, the country of production, the coordinates of every plot, the date and time of production, the names and addresses of upstream suppliers, evidence of legality under local law, and the risk assessment and mitigation conclusion. Once it is submitted the system issues a reference number. The importer enters that number in the EU customs declaration, and the number travels further down the supply chain.
The amendment published in December 2025, (EU) 2025/2650, loosened one link: downstream operators and other traders no longer have to file their own DDS, but they must keep and pass on the reference number of the first DDS, and they must report annual traded volumes. Micro and small primary producers can use a simplified declaration. The fifth edition of the Commission official FAQ has a line that sums up the whole chain: no information, no market.
The route Lao Zhou eventually got working looks like this. The buyer opens the case in TRACES and the system generates a barcoded draft. Lao Zhou packages the plot data, the supplier records and the legality documents and sends them over. The buyer ticks the confirmation, submits, and receives a reference number. The number goes into the customs declaration. Any cell on that chain that does not reconcile stops the container at the port.
Coordinates, four hectares, and the points that do not line up
Coordinates are plot-level, in WGS84 decimal degrees, with at least six decimal places. Above four hectares a polygon boundary is mandatory. At four hectares or below, a single point will do.
Lao Zhou first version of the data set was tapped out on phones in Amap, which exports GCJ-02, the shifted coordinate system used in China. It sits 300 to 500 metres away from WGS84. The system raised no error; the satellite imagery simply did not agree. The Dutch buyer bounced it the same day. Buyers tend to read that as fabricated data, when in fact it is a coordinate system mistake.
There is another point worth thinking through: coordinates mark where the tree grew, not where the board was made. Lao Zhou was using eucalyptus veneer imported from Vietnam as his core, so the coordinates had to come from the logger on the Vietnamese side. The small Vietnamese mill could not even produce a forest rights certificate. Two months passed and it offered three points, seven kilometres apart from each other. In the end Lao Zhou switched his core to local Shandong poplar, at 0.35 yuan more per sheet of veneer.
Risk tiers and the calendar: China sits in the low-risk tier
The EU sorts producing countries into three tiers, and the tier decides how much work your buyer has to do. Low risk allows simplified due diligence, with no full risk assessment and no mitigation measures. Standard risk means the full due diligence process. High risk adds on-site verification, sampling and testing, and third-party checks. Enforcement scales the same way: member states must check at least 1% of operators sourcing from low-risk countries, 3% from standard-risk countries and 9% from high-risk countries, plus 9% of product volume from high-risk origin. The top penalty is 4% of EU turnover, alongside confiscation of goods and revenue, exclusion from EU public procurement and public naming.
The first country list landed on 22 May 2025 through Implementing Regulation (EU) 2025/1093: 140 countries classified low risk, 50 standard risk, and only four high risk, namely Belarus, Myanmar, North Korea and Russia. China is in the low-risk tier. The European Parliament voted against the list in July 2025, calling the methodology opaque, but the Commission adopted it anyway and it is legally in force. It will be updated periodically, so check the current version before you quote a price.
Low risk is not a free pass. The rule carries a condition that is easy to miss: every input must come from a low-risk country, with no mixing with standard-risk, high-risk or unknown-origin material. That is exactly where Lao Zhou got caught. His core veneer was Vietnamese eucalyptus, and Vietnam is not in the low-risk tier. Mix it in and the consignment drops out of the simplified channel and back into full due diligence, with the buyer money and time going up alongside it.
Guidance published in May 2026, now in its third edition, relaxed things for low-risk chains: no need for in-depth data collection plot by plot, no need for individual land titles, no need to compile an exhaustive list of applicable laws. Nobody is relaxing the mixing rule for you.
The calendar moved twice. Large and medium operators were originally due on 30 December 2024, pushed at the end of 2024 to 30 December 2025, and pushed again by (EU) 2025/2650, published on 23 December 2025, to 30 December 2026. Micro and small operators in the timber sector follow the same date as the large ones; micro and small businesses in the other commodities have until 30 June 2027. The EU information system was shut for rebuilding from 16 February 2026 and only reopened in July. Two postponements is enough. Do not bet on a third.
Lao Zhou eleven months: 15,600 yuan for coordinates, USD 23,400 for time
October 2025. Lao Zhou took the checklist to his customs broker first. The broker told him this had nothing to do with customs. That was the moment he understood that EUDR is a sourcing problem, not a paperwork problem.
November. A third party went out across eleven townships to survey plot boundaries. More than sixty plots, 260 yuan each, 15,600 yuan spent.
December. The Vietnamese veneer supplier could not supply coordinates. Switch to local poplar, 630 yuan more per 40-foot container.
January 2026. The first DDS was rejected. Lao Zhou had stated a quantity of 1,800 sheets; the buyer reported 34.2 m3. The two numbers did not match.
February. A consultancy that works on FSC produced the annual due diligence report. 32,000 yuan a year.
March, the price conversation. He asked for 150 US dollars more per 40-foot container; the buyer would only accept 90. Across 260 containers a year, the compliance cost he swallowed himself came to 23,400 US dollars.
The rest of the time went on paperwork for six second-tier suppliers: supply records, logging permits, forest rights documents. Lao Zhou verdict afterwards was that he took the 90 dollars because losing the account meant losing it for good. Every plywood enquiry from Europe now starts with a question about the DDS reference number.
Five straight answers for exporters
First, do not wait to be chased. The pressure always reaches the factory in the end. People who move early put the compliance cost into their quote; people who move late pay demurrage at the port.
Second, get the coordinates done first. Coordinate system, four hectares, polygons. Get those three right and you save two months.
Third, build the supplier ledger now. Who supplied it, which forest, which day, where the evidence sits. Miss one and the chain breaks, and a broken chain has no market.
Fourth, do not waste China low-risk card. China is on the low-risk list, but one input from a standard-risk country closes the simplified channel and the maths has to be redone.
Fifth, reconcile the HS code with your buyer and negotiate the price rise early. Compliance is a recurring cost, not a one-off surcharge on a single shipment.
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