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Independent R&D project · Cologne

EUDR · Article 38(2) and 38(3)Adopted, not yet applicable

EUDR application dates: 30 December 2026 and 30 June 2027

Application date: December 30, 2026

Published by Luiz Hogrefe: August 22, 2026

What changed

Regulation (EU) 2023/1115 is in force, but its core obligations are not yet. Article 38(2) sets Articles 3 to 13, 16 to 24, 26, 31 and 32 to apply from 30 December 2026. Article 38(3) gives its own date to operators who are natural persons or micro and small undertakings established as such by 31 December 2024: for them the same articles apply from 30 June 2027, except as regards products covered by the Annex to Regulation (EU) No 995/2010. Among those articles is Article 9(1)(d), the plot geolocation duty.

Who is affected

Every operator and trader in the coffee, cocoa, soy, cattle, wood, rubber and oil palm chains placing products on the European Union market or exporting from it. The second date is not a general extension: it turns on who the operator is and when it was established.

What to do

Work out which of the two dates the company falls under by reading the Article 38(3) criterion rather than the date that circulates in summaries. Anyone under 30 December 2026 needs plot-level geolocation ready before then, because it is data that originates at source and cannot be reconstructed at the port.

Related deadlines

  • December 30, 2026. Start of application of the EUDR core obligations for medium and large operators (Article 38(2)).
  • June 30, 2027. Start of application of the same obligations for natural persons and micro and small undertakings established by 31 December 2024 (Article 38(3)).

Primary source

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02023R1115-20251226

Checked against the primary source by Luiz Hogrefe on August 22, 2026; source opened: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02023R1115-20251226.

Information verified against a primary source on the date indicated. This content is informational and does not constitute legal advice. Confirm applicability to your specific situation with your own advisor.

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