EUDR for beef & meat importers
Beef is in scope. Cattle is one of the seven commodities, and Annex I covers live cattle, fresh, chilled and frozen beef, edible offal and some prepared bovine meat. [Reg. 2023/1115, Art. 2(1) & Annex I] If you import beef into the EU, you are the operator: you run full due diligence, geolocate where the cattle were kept, and file the Due Diligence Statement before the goods clear customs. [Reg. 2023/1115, Art. 4]
Which cattle products are in scope
Annex I lists the cattle chain from the live animal through to prepared meat: live cattle (CN 0102 21 and 0102 29), meat of cattle fresh or chilled (ex 0201) and frozen (ex 0202), edible bovine offal (ex 0206 10, ex 0206 22, ex 0206 29), and certain other prepared or preserved bovine meat (ex 1602 50). [Reg. 2023/1115, Annex I] The "ex" prefix matters: these headings cover meat of cattle specifically. Bison and buffalo fall under related tariff lines but are not "cattle" for the EUDR, so a shipment of buffalo meat is a different question from a shipment of beef.
As the importer, you are the operator
The EUDR pins the heaviest obligation on the person who first places a product on the EU market. An importer bringing beef in from Brazil, Argentina, Uruguay, the United States or anywhere else outside the EU is exactly that person. [Reg. 2023/1115, Art. 2(15) & Art. 4(1)] That means you carry the full due diligence duty — collect the information, assess the risk, mitigate it — and you file the Due Diligence Statement in the EU information system, getting a reference number that travels with the consignment. [Reg. 2023/1115, Art. 4(2) & Art. 8] You cannot place the goods, or have them released for free circulation, without it. There is no downstream shortcut here: the importer is the operator, and the DDS is yours to file.
Geolocation for cattle: the establishments, not a single farm
Cattle geolocation trips importers up because it is not one coordinate. The due diligence information must include the geolocation of all plots of land where the relevant commodity was produced — for cattle, the establishments where the animals were kept — with coordinates for every plot and polygons for any plot larger than four hectares, together with the country of production and the relevant dates. [Reg. 2023/1115, Art. 9 & Art. 2(28)] For a beast that moved between a breeding property, a backgrounding block and a feedlot before slaughter, that can mean several locations per animal. This is the practical heart of cattle compliance: your supplier has to trace each animal back to the land it was kept on, and hand you geolocation for all of it.
Origin risk: Brazil is standard, not high
A point importers get wrong: Brazil, the largest beef origin for the EU, is standard risk under Implementing Regulation (EU) 2025/1093 — not high risk. [Impl. Reg. 2025/1093] Standard risk means full due diligence applies. Argentina and Uruguay are also standard risk. The United States is low risk, which unlocks simplified due diligence — you collect the information and confirm negligible risk, without the full risk-assessment and mitigation steps. [Impl. Reg. 2025/1093] The list is reviewed and can move, so confirm the tier for each origin before you rely on a simplified route. A "high risk" tag would mean enhanced scrutiny and higher inspection rates; only Belarus, Myanmar, North Korea and Russia sit there, and they are not beef origins that concern most importers.
What to ask your cattle supplier for
Whatever the origin, you will need a consistent data pack from every supplier before a consignment can be declared. For each lot, request: [Reg. 2023/1115, Art. 9 & Art. 2(28)]
- Geolocation of the establishments where the cattle were kept — coordinates for all plots, polygons for plots over 4 hectares.
- The relevant dates — the production/keeping period.
- Country of production (which sets the risk tier).
- Legality evidence for the country of origin.
- Traceability from animal to land, so movements between properties are captured, not just the last one.
What this determines — and what it doesn't
Screening your beef lines tells you scope, your role as operator, your deadline and the documentary obligations you owe. It does not verify that any pasture or feedlot is deforestation-free — that depends on the geolocation-plus-evidence your suppliers provide and any satellite check. You don't need a traceability platform to begin. You need to know that you are the operator, what geolocation the cattle chain owes you, and exactly what to demand from each supplier.
General information about Regulation (EU) 2023/1115, not legal advice — and not a deforestation assessment. This kind of screening determines your scope, role, deadline and documentary obligations; it does not verify that any plot of land is deforestation-free. Confirm your classification with counsel before relying on it for a market-access decision.
Know your DDS and geolocation duties before the next consignment
You don't need a traceability platform to start — you need to know you are the operator, what the cattle chain owes you in geolocation, and exactly what to ask each supplier for. The EUDR position report screens your products against Regulation (EU) 2023/1115, names your role and deadline, tiers your origin countries, and hands you ready-to-send supplier data-request letters.
Check my cattle products → get my EUDR position reportQuestions
Is beef covered by the EUDR?
Yes. Cattle is one of the seven commodities. Annex I of Regulation (EU) 2023/1115 covers live cattle (CN 0102 21, 0102 29), meat of cattle fresh or chilled (ex 0201) and frozen (ex 0202), edible bovine offal (ex 0206), and certain prepared or preserved bovine meat (ex 1602 50). Bison and buffalo are not cattle for this purpose.
Does a beef importer have to file a Due Diligence Statement?
Yes. If you are the first to place the beef on the EU market — which an importer bringing beef in from outside the EU is — you are the operator. You run full due diligence and file the Due Diligence Statement before the goods are placed on the market or cleared through customs, and you keep the reference number.
What geolocation does the EUDR require for cattle?
For cattle you need the geolocation of the establishments where the animals were kept, plus the coordinates of the plots of land connected to that production. Coordinates are required for all plots, and polygons for plots larger than four hectares, along with the country of production and the relevant dates.
Is beef from Brazil high risk under the EUDR?
No. Under Implementing Regulation (EU) 2025/1093, Brazil is classified as standard risk, not high risk. Standard risk means full due diligence. Argentina and Uruguay are also standard risk, while the United States is low risk, which allows simplified due diligence. The benchmarking list can change, so re-check the tier for each origin.
Sources
- Regulation (EU) 2023/1115 (EU Deforestation Regulation) — https://eur-lex.europa.eu/eli/reg/2023/1115/oj — Art. 2(1) & Annex I (cattle in scope: CN 0102 21/29, ex 0201, ex 0202, ex 0206, ex 1602 50), Art. 2(15) (operator), Art. 4 & Art. 8 (operator obligations and the DDS), Art. 9 & Art. 2(28) (geolocation).
- Implementing Regulation (EU) 2025/1093 (country risk benchmarking) — https://eur-lex.europa.eu/eli/reg_impl/2025/1093/oj — Brazil, Argentina and Uruguay standard risk; United States low risk; Belarus, Myanmar, North Korea, Russia high risk.
- Regulation (EU) 2025/2650 (amending 2023/1115; dates of application and simplification) — https://eur-lex.europa.eu/eli/reg/2025/2650/oj — application dates and downstream obligations.
- European Commission — EUDR implementation, guidance & FAQ — https://green-business.ec.europa.eu/deforestation-regulation-implementation_en — draft delegated act of 4 May 2026 proposing to add frozen cattle tongues (CN 0206 21).