EUDR for US exporters
If you are a US company shipping soy, wood, paper, beef, leather or other relevant products into the EU, you are almost never the operator under the EUDR — your EU importer is, and it files the Due Diligence Statement. [Reg. 2023/1115, Art. 2(15)] There is no US federal equivalent, so you feel this through your EU customer's data demands, not a US filing. The USA is a low-risk country, so US-produced goods get simplified due diligence — but your buyer still needs plot geolocation from you. [Impl. Reg. 2025/1093, Art. 1]
Does the EUDR apply to US companies?
Not the way an EU business is caught. The EUDR applies at the moment a relevant product is first placed on the EU market, or exported from it. The person doing that is the operator, and the operator runs due diligence and files the DDS. [Reg. 2023/1115, Art. 2(15) & Art. 4] A US exporter selling into the EU is not the one placing goods on the EU market — its EU importer is — so the filing obligation sits with the importer.
There is also no US federal law that mirrors the EUDR. Nothing in Washington requires you to run EUDR-style due diligence or file anything. So the regulation reaches US soy crushers, sawmills, paper mills and beef processors the same way it reaches any non-EU supplier: through the contract. Your EU buyer cannot file a defensible DDS without origin data it can only get from you, so the ask lands in your purchase orders and vendor questionnaires.
What the US's low-risk status buys you
The Commission benchmarked countries into three tiers. The United States is low risk. [Impl. Reg. 2025/1093, Annex] For goods produced in the US, your EU customer can use simplified due diligence: it still collects the origin information, but skips the full risk-assessment and mitigation steps. [Reg. 2023/1115, Art. 13] For US soy, wood and paper, and US beef and leather, that is a meaningful cut in your buyer's workload — and a genuine advantage you can put in front of an EU customer weighing US supply against a standard-risk origin like Brazil.
Why geolocation is the sticking point
The Article 9 information set includes the geolocation of all plots of land where the commodity was produced — coordinates, and polygons for any plot over 4 hectares. [Reg. 2023/1115, Art. 9(1)(d) & Art. 2(28)] That is where US commodity chains strain. American grain, timber and cattle systems are built to aggregate: soybeans from hundreds of farms flow through an elevator and a crusher; logs from many tracts hit one mill; cattle move through auctions and feedlots before slaughter. None of that infrastructure was designed to carry farm-level coordinates to the export dock. Meeting the geolocation ask usually means pushing traceability back through the elevator, the mill or the packer to the field, tract or ranch of origin — the real work behind an EUDR-ready US supply chain.
What your EU customer will ask you for
Whether you sell a first-stage commodity or a finished good, the buyer needs a clean origin file per consignment: [Reg. 2023/1115, Art. 9(1) & Art. 2(28)]
- Plot geolocation — coordinates for every plot of production, and polygons for plots larger than 4 hectares.
- Harvest or production dates.
- Country of production — which sets the risk tier.
- Legality evidence under US law (land use, environmental, and applicable trade rules).
- A DDS reference number, where you have exported as an operator and already filed one.
Which deadline sits behind the request
The date driving your EU customer is the operator's date, not yours. Medium and large operators are on 30 December 2026; micro and small operators on 30 June 2027, except the timber carve-out where small wood operators keep the earlier date. [Reg. 2025/2650] US wood and paper exporters should expect data requests first, because their buyers do not get the later small-operator date.
What this determines — and what it doesn't
Screening tells you your position: whether your product is in scope, that you are a supplier rather than the operator, the origin risk tier your goods carry, and exactly what your EU customer will demand. It does not verify that any plot of land is deforestation-free — that depends on the geolocation-plus-evidence your own producers provide and any satellite check the EU operator runs. You don't need a traceability platform to begin; you need to know your role and what to collect.
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.
Get ahead of your EU buyer's data demand
Before your next EU order stalls on a geolocation request, get your position clear. The EUDR position report screens your products against Regulation (EU) 2023/1115, confirms you are the supplier and not the operator, tiers your origin countries, and hands you ready-to-send supplier data-request letters so you can push the coordinates ask back to the field.
Check if my product is caught → get my EUDR position reportQuestions
Does the EUDR apply to US companies?
Not directly. A US company that sells relevant goods to an EU buyer is not the operator. The operator is the EU business that first places the goods on the EU market — usually your EU importer — and that party files the Due Diligence Statement. There is no US federal EUDR-equivalent, so US exporters feel the regulation through their EU customers' data demands, not through a US filing.
Is the United States a low-risk country under the EUDR?
Yes. Implementing Regulation (EU) 2025/1093 classifies the United States as low risk, so US-produced soy, wood, paper and beef qualify for simplified due diligence. The risk tier follows the country of production, so goods grown elsewhere and merely shipped from a US port keep their origin's tier.
Why is geolocation the hard part for US commodity exporters?
Even under simplified due diligence, your EU buyer must collect the geolocation of every plot of production — coordinates, and polygons for plots over 4 hectares. US grain, timber and cattle supply chains pool material from many farms and are not built to carry farm-level coordinates to the export point, so mapping production back to plots is the main lift.
What data will my EU customer ask a US exporter for?
For each consignment: the plot geolocation of production (coordinates, and polygons for plots over 4 hectares), harvest or production dates, the country of production, and evidence of legal production. Where you have already filed a Due Diligence Statement as an operator or exporter, the DDS reference number too.
Sources
- Regulation (EU) 2023/1115 (EU Deforestation Regulation) — https://eur-lex.europa.eu/eli/reg/2023/1115/oj — Art. 2(15) (operator definition), Art. 4 (placing on the market and operator obligations), Art. 9(1) & Art. 2(28) (information incl. geolocation and polygons), Art. 13 (simplified due diligence for low-risk countries).
- Implementing Regulation (EU) 2025/1093 of 22 May 2025 (country risk benchmarking) — https://eur-lex.europa.eu/eli/reg_impl/2025/1093/oj — Art. 1 & Annex (United States classified low risk; risk tier by country of production).
- Regulation (EU) 2025/2650 (amending 2023/1115; dates of application) — https://eur-lex.europa.eu/eli/reg/2025/2650/oj — Art. 1 (30 December 2026 / 30 June 2027 application dates and the timber exception).
- European Commission — EUDR implementation, guidance & FAQ — https://green-business.ec.europa.eu/deforestation-regulation-implementation_en — role of non-EU suppliers and the information they provide up the chain.