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    QHSEtech
    Updated 21 October 2026
    Software Guide · Updated 21 October 2026

    EUDR software: plots, risk, and the statement

    EUDR software scope depends first on the product, the actor's role and the applicable due-diligence regime. The first operator placing a relevant product on the EU market or exporting it carries the main statement responsibility under the revised model; downstream actors and qualifying micro or small primary operators have different duties. Define that role before specifying plots, risk work and Information System handoffs. Dates and actor distinctions below were checked against European Commission pages and EUR-Lex on 21 October 2026.

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    Editorial responsibility: Dimitris Mitsios (Founder of The QHSE Standard; product marketing at Tekmon) · Tekmon pays for sponsored placements on this site (disclosure) · How pages are made · LinkedIn · Content date: 21 October 2026

    On this page (8 sections)

    The dates, as they currently stand

    Per the European Commission, following amendments in December 2024 and December 2025, the Regulation applies from 30 December 2026 for large and medium operators, and from 30 June 2027 for micro and small operators — except micro and small operators already covered by the EU Timber Regulation, who are in scope from 30 December 2026. European Commission: regulation on deforestation-free products The consolidated legal text is narrower on the later date: it applies only to operators that are natural persons or micro or small undertakings established by 31 December 2024, and never to the timber products listed in the EU Timber Regulation's annex. Regulation (EU) 2023/1115 (EUDR), consolidated text of 18 September 2026 on EUR-Lex

    If you read an earlier version of this page, it said the regulation applied from 30 December 2025 and 30 June 2026. That was wrong: those dates were superseded by the amendments and we had not updated it. The correction matters in both directions — you have more time than that page implied, but the large-operator date of 30 December 2026 is now close rather than already past.

    The commodities in scope are cattle, cocoa, coffee, oil palm, rubber, soya and wood, together with listed derivative products. Whether a specific product of yours is in scope is a question for the combined nomenclature codes in the Regulation's annex, not for a vendor's marketing page. Regulation (EU) 2023/1115 (EUDR), consolidated text of 18 September 2026 on EUR-Lex

    Commission Delegated Regulation (EU) 2026/2102 of 13 July 2026 amends Annex I, the product list; it was published in the Official Journal on 17 September 2026 and has been in force since the next day. Its additions apply only from 30 December 2027: soluble coffee (coffee extracts, essences and concentrates), frozen cattle tongues, and a set of derivatives made using oil palm, among them hydrogenated or chemically modified palm oils, crude glycerol, certain fatty alcohols, acids, esters, amines and amides, soaps, polyethers and other chemical preparations. The same act narrows heading 4012 (retreaded and used tyres, treads and flaps) to tyre treads only, while new pneumatic tyres stay in scope, and takes out cattle hides, skins and leather, conveyor and transmission belts and other articles of vulcanised rubber, soya beans for sowing, and aircraft and motor-vehicle seats. It also places samples, products sent for testing, packing material, waste, used and second-hand goods, and products used to make medicines outside scope, within the limits each entry sets. Commission Delegated Regulation (EU) 2026/2102 on EUR-Lex European Commission news, 13 July 2026: product scope and Information System measures

    The act belongs to a simplification package. On 4 May 2026 the Commission published its review of the Regulation, COM(2026) 191, alongside updated guidance and FAQs and a draft of the product-list act for feedback; the review concluded that proposing further amendments to the legal text was not appropriate, so that the rules stay stable. On 13 July the Commission adopted the delegated act with new Information System rules and described them as completing the May package. European Commission: EUDR simplification review, COM(2026) 191 of 4 May 2026 European Commission news, 13 July 2026: product scope and Information System measures

    Country classification still rests on Commission Implementing Regulation (EU) 2025/1093 of 22 May 2025. It names four high-risk countries (Belarus, Myanmar, North Korea and Russia) and a list of low-risk countries; every other country is standard risk. On 21 October 2026 EUR-Lex recorded no act amending it, and the Commission's country page named no later classification. Article 29 lets the Commission review the list whenever new evidence warrants, so record which version each risk conclusion relied on. Commission Implementing Regulation (EU) 2025/1093 (country classification) on EUR-Lex European Commission: EUDR countries and benchmarking Regulation (EU) 2023/1115 (EUDR), consolidated text of 18 September 2026 on EUR-Lex

    What changes on 30 December 2026

    This is the date on which the main obligations start for most companies, under Article 38 of the consolidated text as read on 21 October 2026. Regulation (EU) 2023/1115 (EUDR), consolidated text of 18 September 2026 on EUR-Lex

    • Who starts. Every operator except one deferred group: operators that are natural persons or micro or small undertakings established by 31 December 2024 start on 30 June 2027, but not for the timber products listed in the EU Timber Regulation's annex, where 30 December 2026 applies to them too. A micro or small undertaking established after 2024 starts on 30 December 2026. The duties of downstream operators and traders in Article 5 are among the articles that apply from this date.
    • The statement and its reference number. Before placing a relevant product on the market or exporting it, the operator files a due diligence statement in the Information System, keeps it for five years and gives its reference number to the downstream operators and traders it supplies. A micro or small primary operator files a one-time simplified declaration instead and passes on the declaration identifier it receives.
    • Downstream records. Downstream operators and traders that are not SMEs register in the Information System before they trade. All of them keep supplier and customer names and addresses, plus the reference number or declaration identifier where the supplier is an operator, for at least five years.
    • The Information System. Statements and declarations go into the Information System, a tool on the Commission's TRACES platform, by web form or through an API. It reopened at the end of June 2026, and its rules (Implementing Regulation (EU) 2024/3084) were amended in July by Implementing Regulation (EU) 2026/1565. Filings on its training (acceptance) server have no legal value. European Commission: the EUDR Information System European Commission news, 13 July 2026: product scope and Information System measures
    • Stock placed earlier. Apart from timber covered by the EU Timber Regulation, which has its own transition rules, a product placed on the market before its operator's start date stays outside the main obligations; the Commission's guidance asks for verifiable evidence of that earlier placing. Commission guidance document for the EUDR, C/2026/3896, on EUR-Lex
    • Not yet. Products added by Delegated Regulation (EU) 2026/2102 are covered only from 30 December 2027. Commission Delegated Regulation (EU) 2026/2102 on EUR-Lex

    Three records to test after establishing the actor's duties

    Plot or production-place evidence

    Establish the geolocation evidence required for the product and actor. Qualifying micro or small primary operators from low-risk countries can use the revised simplified regime; do not impose one polygon workflow on every actor.

    Risk assessment where required

    For the full due-diligence path, retain the assessment and reasoning. Operators using simplified due diligence for low-risk sourcing are not required to perform the same risk assessment unless relevant risk information becomes known.

    Statement, declaration or reference handoff

    The first operator carries the main due-diligence-statement responsibility under the revised model. Downstream actors mainly register or collect reference numbers in specified cases, while qualifying primary operators use a simplified declaration. Test the workflow that applies to your role.

    Test it on your worst supplier, not your best

    1

    Load a supplier with partial plot data

    Use one where coordinates are missing, imprecise or cover more land than the consignment. Establish what the system does with incomplete geolocation — blocks, flags, or accepts and lets you submit anyway.

    2

    Collect a polygon from someone without a smartphone

    Smallholder collection is the practical constraint in cocoa and coffee. Establish what the collection route actually is, who does it, whether it works offline, and what it costs per plot.

    3

    If full due diligence applies, test the risk conclusion

    Ask where the assessment reasoning is stored, not just the score. Then change one input — a country benchmark or supplier response — and confirm the prior conclusion and its basis are retained. For eligible low-risk simplified due diligence, test how relevant risk information triggers the full assessment path.

    4

    Attempt the applicable submission with an unresolved flag

    Try to prepare the due diligence statement or simplified declaration that applies to the actor while required evidence is unresolved. Establish whether the system blocks, flags or merely formats the record.

    5

    Trace one consignment through the applicable records

    Retrieve the required production-place evidence, reference numbers, assessment where required, and statement or declaration as one reviewable set. Do not demand the same bundle from every actor or regime.

    Products with EUDR-specific evidence in this catalogue

    The rule requires both a dedicated EUDR Compliance tag and a sourced capability naming EUDR, deforestation, plot geolocation or the due-diligence statement. General ESG, supplier-questionnaire or sustainability-reporting scope does not qualify.

    Ordered by how closely our sources document this process, not by quality. Sponsored placements are labelled. How lists are ordered

    Same rule for every product: tagged “EUDR Compliance”, with a sourced EUDR plot, deforestation-risk or due-diligence-statement capability in its record, or one the vendor stated to us, labelled as vendor-stated. 7 qualify.

    • EUDR Passport

      Documented entry point: EUDR due diligence. Demo task: load an incomplete plot, retain an unresolved risk flag and establish whether the proposed application blocks or prepares the applicable declaration or statement. Source: trusty.report

    • osapiens HUB

      Documented entry point: EUDR due diligence. Demo task: load an incomplete plot, retain an unresolved risk flag and establish whether the proposed application blocks or prepares the applicable declaration or statement. Source: osapiens.com

    • Coolset

      Documented entry point: EUDR due diligence. Demo task: load an incomplete plot, retain an unresolved risk flag and establish whether the proposed application blocks or prepares the applicable declaration or statement. Source: coolset.com

    • IntegrityNext

      Documented entry point: EUDR due diligence. Demo task: load an incomplete plot, retain an unresolved risk flag and establish whether the proposed application blocks or prepares the applicable declaration or statement. Source: integritynext.com

    • Polygon One

      Documented entry point: EUDR due diligence. Demo task: load an incomplete plot, retain an unresolved risk flag and establish whether the proposed application blocks or prepares the applicable declaration or statement. Source: polygon-one.com

    • Satelligence

      Documented entry point: EUDR due diligence. Demo task: load an incomplete plot, retain an unresolved risk flag and establish whether the proposed application blocks or prepares the applicable declaration or statement. Source: satelligence.com

    • Source Intelligence

      Documented entry point: EUDR due diligence. Demo task: load an incomplete plot, retain an unresolved risk flag and establish whether the proposed application blocks or prepares the applicable declaration or statement. Source: sourceintelligence.com

    Questions that separate candidates

    What happens when plot geolocation is missing or imprecise?
    What is the actual collection route for a supplier without a smartphone?
    Is polygon collection priced per plot, per supplier, or per licence?
    Where is the risk assessment reasoning stored when the full assessment path applies?
    Is a prior conclusion retained when an input changes?
    Does the platform submit the applicable statement or declaration, prepare it, or only store its reference?
    Can a statement be generated while a plot is unverified?
    Which deforestation and country benchmark data sources are used, and when refreshed?
    Can one consignment be traced to all its plots in a single export?
    How are consignments handled that mix compliant and unverified sources?

    Sources and evaluation limits

    9 sources

    All opened on 21 October 2026, the EUR-Lex documents on eur-lex.europa.eu itself. Application dates and scope: European Commission: regulation on deforestation-free products. Legal text: Regulation (EU) 2023/1115 (EUDR), consolidated text of 18 September 2026 on EUR-Lex, the consolidated version that includes the product-list changes. Product list: Commission Delegated Regulation (EU) 2026/2102 on EUR-Lex and European Commission news, 13 July 2026: product scope and Information System measures. Revised actor responsibilities and simplifications: European Commission: EUDR simplification review, COM(2026) 191 of 4 May 2026 and Commission guidance document for the EUDR, C/2026/3896, on EUR-Lex. Filing: European Commission: the EUDR Information System. Country risk classes: Commission Implementing Regulation (EU) 2025/1093 (country classification) on EUR-Lex and European Commission: EUDR countries and benchmarking.

    The Regulation has been amended twice by the EU legislators and once, on its product list, by the Commission, and may be amended again; confirm the operative dates and your own scope before acting, and treat any secondary summary — including this page — as something to check rather than rely on. Nothing here is legal advice, and whether a specific product falls in scope is determined by the nomenclature codes in the Regulation, not by a software category.

    We do not rank products here and have tested none hands-on. A product is named only when its researched record contains EUDR-specific sourced evidence under the same published rule; general supplier or sustainability scope is not treated as proof of this workflow.

    What we could not verify (21 October 2026): we did not open the Commission's FAQ document, which is offered only as a file download, or the staff working document on the product-scope method. Of Implementing Regulation (EU) 2026/1565 we read the title and dates, not the detailed filing rules, and we did not sign in to the Information System, so its functions are described from the Commission's pages rather than tested. Article 38(3) speaks of operators; we did not establish how the June 2027 date applies to a micro or small downstream operator or trader, so ask your competent authority. Finding no amendment to the country list on EUR-Lex describes that day only.

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    Frequently Asked Questions

    When does EUDR actually apply?
    Per the European Commission page and the consolidated text on EUR-Lex, both read on 21 October 2026: from 30 December 2026 for large and medium operators, and from 30 June 2027 for micro and small operators — except micro and small operators already covered by the EU Timber Regulation, who are in scope from 30 December 2026. The legal text gives the later date only to operators that are natural persons or micro or small undertakings established by 31 December 2024, and not for timber products listed in the EU Timber Regulation's annex. Products added by Delegated Regulation (EU) 2026/2102, such as soluble coffee, frozen cattle tongues and certain palm-oil derivatives, are covered from 30 December 2027. The dates were amended in December 2024 and December 2025, so check the Commission page rather than any secondary source.
    What did Delegated Regulation (EU) 2026/2102 change?
    It amended Annex I, the product list, and has been in force since 18 September 2026. Its additions, which are soluble coffee, frozen cattle tongues and a set of palm-oil derivatives, apply from 30 December 2027. It removed cattle hides, skins and leather, retreaded and used tyres (tyre treads and new tyres stay in), soya beans for sowing, conveyor belts and other vulcanised-rubber articles, and aircraft and motor-vehicle seats, and it put samples, test material, packing, waste and used goods outside scope within the limits each entry sets. Check your own nomenclature codes against the consolidated Annex I on EUR-Lex (read 21 October 2026).
    What is the hardest part to implement?
    It depends on the actor and regime. For a full due-diligence workflow, collecting and reconciling plot geolocation can dominate the work, especially with smallholders and limited connectivity. A qualifying micro or small primary operator under the simplified regime may use different production-place evidence, including a postal address in the specified case. Define the applicable evidence route before comparing platform features.
    Does the software submit the due diligence statement?
    First establish your actor role under the revised EUDR model. The first operator carries the main statement responsibility; downstream operators and traders have narrower registration or reference-number duties in specified cases, and qualifying micro or small primary operators use a simplified declaration. Then establish whether the proposed system submits, prepares or only stores the applicable record, and what evidence you retain.
    Is a satellite deforestation alert enough?
    No. Where the full risk-assessment path applies, an alert or its absence is one input rather than the assessment itself; the conclusion and reasoning still need a defensible record. Under eligible low-risk simplified due diligence, the full assessment is not required unless relevant risk information arises. Test how the system preserves that distinction and escalates an exception.
    Which products should we evaluate?
    In our catalogue, the 7 products that meet this guide's rule (a matching tag and a sourced EUDR plot, deforestation-risk or due-diligence-statement capability or one the vendor stated to us) are EUDR Passport, osapiens HUB, Coolset, IntegrityNext, Polygon One and 2 more, in documented-match order (see the list on this page). That order reflects documentation, not quality; no product is recommended. Use the questions on this page against any additional candidates without treating an unchecked name as researched.