Moving, exporting or placing deforestation-free products on the market in Northern Ireland
Steps businesses must take to make sure their products meet the EU regulation on deforestation-free products (EUDR) if they market them in, move them to or export them from Northern Ireland.
The EU’s regulation on deforestation-free products (EUDR) will apply in Northern Ireland, replacing the European Timber Regulation (EUTR). EUDR will not apply in Great Britain (England, Scotland and Wales).
However, the government has announced its intention to introduce deforestation regulations in Great Britain, meaning if you supply certain forest risk commodities or wood products in Great Britain, you may need to comply with any future deforestation regulations.
The government will soon consult on the proposed policy in Great Britain, aiming to ensure aspects of the scope and information requirements are broadly the same as those of the EUDR. This is to reduce regulatory divergence between Great Britain and Northern Ireland and support trade with the EU.
Read more about the UK’s approach to deforestation regulations.
Understanding the EUDR
EUDR will regulate certain commodities and products that are imported or moved into Northern Ireland, made available on the Northern Ireland market or exported from Northern Ireland outside the UK and the EU.
Under EUDR, the products in your supply chains must be:
- deforestation-free
- compliant with the relevant law in their country of origin
- covered by a ‘due diligence statement’ (DDS) or, in the case of micro or small primary operators, a one-off simplified declaration
A deforestation-free commodity or product means it:
- has not been produced on land that was deforested after 31 December 2020
- contains or has been made using wood, the wood must have been harvested from a forest without inducing forest degradation after 31 December 2020
Products and commodities in scope
You will need to meet these rules for the following products (unless they meet an exemption):
- cattle
- cocoa
- coffee
- oil palm
- rubber
- soya
- wood
- products made from these commodities (such as wooden furniture or chocolate)
You can read the full list of products in annex I of Regulation (EU) 2023/1115 and the EU’s final delegated act of the regulation.
Packing materials
You must meet the rules for packing materials with the following Harmonized System (HS) codes:
- HS 4819 – cartons, boxes, cases, bags and other packing containers of paper, paperboard, cellulose wadding or cellulose fibres
- HS 4415 – packing cases, boxes, crates, drums and similar packings of wood; pallets, box pallets and other load boards
- HS 4401 – fuel wood, wood in chips or particles, sawdust and wood waste and scrap
- HS 4405 – wood wool and wood flour
- HS 4416 – casks, barrels, vats, tubs and other coopers’ products and parts thereof, of wood
This only applies if you sell or export the packing item itself or it adds value to another product you sell or export.
Packing materials or containers are not in scope if you use them only to support, protect or carry another product. This applies to both single-use packing and reusable packing.
For example, if you sell a piece of jewellery in a:
- high-quality wooden jewellery box that is durable and intended to be reused, the rules would apply as it adds value to the product
- thin cardboard sleeve used purely to protect the item during shipping, the rules would not apply
Exemptions
Your products may be exempt from the rules, such as if they are:
- product samples
- made entirely from recycled materials or second-hand materials
- at the end of their life cycle and would otherwise be discarded
- made from bamboo
- classified as Goods Not For Resale (GNFR)
GNFR are materials, packaging or supplies used strictly to support company logistics and day-to-day operations (such as shipping boxes, pallets or internal print materials) rather than sold as a commercial product.
Check the full list of exemptions in the EU’s final delegated act of the regulation.
Approach in Great Britain
The government has announced its intention to introduce deforestation regulations in Great Britain, meaning if you supply certain forest risk commodities or wood products in Great Britain, you may need to comply with any future deforestation regulations.
The government will soon consult businesses, civil society and international partners on the proposed policy. We will aim to ensure aspects of the scope and information requirements are broadly the same as those of the EUDR. This is to reduce regulatory divergence between Great Britain and Northern Ireland and support trade with the EU.
For more information, read the UK’s approach to deforestation regulations.
When you must meet the rules
You will need to meet the rules from:
- 30 December 2026, if you’re a medium or large operator or a micro or small primary operator (MSPO) already subject to the EU Timber Regulations (EUTR)
- 30 June 2027, if you’re a micro or small primary operator (MSPO) for other in scope commodities
- 30 December 2027, if your business trades newly added palm oil-derived products, including soap and other hygiene products, soluble coffee and frozen cattle tongues covered by the EU’s final delegated act of the regulation
Timber and timber products under the EUTR
If your timber and timber products were produced before 29 June 2023, you must follow the EUTR:
- when placing them on the market between 30 December 2026 and 30 December 2029
- from 31 December 2029
Competent authorities and their role in EUDR
A competent authority is the body responsible for enforcing EUDR.
Who your competent authority is will depend on your product.
If your product is wood and rubber products, the Office for Product Safety and Standards (OPSS) will act as the competent authority.
If your product is cattle, cocoa, coffee, palm oil and soy, the competent authority is the Department of Agriculture, Environment and Rural Affairs in Northern Ireland (DAERA).
Who must meet the rules
You will need to meet different sets of rules depending on the size of your business and your role in the supply chain. You will either be:
- an operator
- a micro or small primary operator (MSPO)
- downstream operator
- trader
To determine your role in the supply chain, you should consider whether you are the first person or business to place the product on the market in Northern Ireland or the EU or export it. MSPOs are a type of operator for the purposes of EUDR, but for clarity this guidance sets out the distinct obligations of non-MSPO operators and MSPOs separately.
If you’re buying a product for your own personal or private use, you do not need to meet these rules.
Operators
You’re an operator if:
- you’re the first person or business to place relevant products on the market in the EU or Northern Ireland
- you’re the first person or business to export the product from Northern Ireland to outside the UK or the EU
- you do not meet the definition of a MSPO
Examples include a:
- meat processor in Northern Ireland who imports beef from Brazil that has not previously been on the Northern Irish or EU market
- timber merchant based in Great Britain who sells wood products to a consumer in Northern Ireland
- Northern Ireland coffee shop who buys coffee beans from a wholesale roastery in Great Britain
Micro or small primary operators (MSPOs)
You’re an MSPO if you are an operator that is:
- a natural person or a micro or small undertaking – check EU Directive 2013/34
- based in a low-risk country (see the EUDR country risk categorisations)
- directly placing relevant products onto the EU or Northern Ireland market, or exporting them from the EU or Northern Ireland
- the primary producer of these products, meaning that you have grown, harvested, obtained or raised the product in the country where you’re based
You may be an operator as well as an MSPO. You can read more about whether you are classed as an MSPO in the EU’s Directive 2013/34/EU.
An MSPO could be a:
- Northern Ireland beef farmer who rears cattle and sells them directly to a local abattoir or meat processor in Northern Ireland
- small private woodland owner in Northern Ireland who harvests timber from their land and sells the raw logs to a Northern Irish sawmill
- small-scale Northern Ireland farm or forestry business that harvests products and exports them directly to a buyer outside the UK or EU, such as the United States
Downstream operators
You’re a downstream operator if you are a person or business that places on the market or exports relevant products made using relevant products, all of which are covered by a due diligence statement or by a simplified declaration.
Examples include a Northern Ireland tyre manufacturer placing tyres (ex HS Code 4011) on the market, which were made using natural rubber (HS Code 4001) purchased from the EU market and covered by a due diligence statement.
Traders
You’re a trader if you’re a person or business making a product available on the market without being the first to place it there, and without further processing it.
An example is a Northern Ireland retailer selling coffee beans if these coffee beans are already covered by a DDS produced by the Northern Ireland importer of the coffee.
Your obligations under EUDR
Depending on your role in the supply chain, your obligations may differ. The obligations outlined below are summarised at a high level. Further guidance on the specific requirements for each role in the supply chain is provided below.
Having a due diligence system to establish that relevant products have a negligible risk of being non-compliant with EUDR.
- operators and micro or small primary operators (MSPO) must have such a system
- downstream operators and traders do not need to have a due diligence system
Providing certain information to demonstrate that due diligence has taken place.
- operators must submit a due diligence statement to the EUDR Information System for all relevant products. Upon submission, the system generates a unique reference number, which may need to be communicated to downstream businesses in the supply chain. Where applicable, the reference number or declaration identifier must also be made available to customs authorities before the relevant products enter Northern Ireland or the EU or are exported from Northern Ireland to outside the UK or the EU. An MSPO does not need to provide due diligence statements for relevant products but must make a one-off simplified declaration. Further guidance on how an MSPO can make this one-off declaration is below
- your one-off declaration will generate a unique declaration identifier number. You must pass this unique identifier number on to the downstream businesses in your supply chain so they can fulfil their own due diligence obligations. which may need to be provided on request by a competent authority and must be communicated to downstream businesses in your supply chain
- you may need to provide your due diligence statement reference number or your unique declaration identifier number to a competent authority on request. Competent authority enforcement is based on risk assessment. If the competent authority requires specific information, they will formally contact you to request this
- downstream operators and traders must keep relevant information for at least five years, listed under Article 5, and provide that information to the competent authorities upon request. Non-SME downstream operators are required to register on the EUDR Information System
Annual reporting of the operation of the due diligence system is for large operators (meaning operators which are not individuals, micro, small or medium enterprises). Downstream operators and traders do not need to produce annual reports.
Operators, including MSPOs: completing due diligence
If you are an operator, you must:
- Maintain a due diligence system to make sure your products continue to be deforestation free.
- Submit a DDS if you are an operator who is not an MSPO, or a one off simplified declaration if you are an MSPO.
Maintain a due diligence system
You must put in place a framework of procedures and measures to ensure you are complying with EUDR. This is called a due diligence system.
To support you in establishing your due diligence systems, the EU Commission will establish 2 repositories for:
- relevant legislation of the country of production, as per Article 2(40) of the EUDR
- certifications schemes applicable to EUDR-relevant commodities
You must update your existing due diligence annually and as needed if there are new developments that affect it.
You must keep a record of any updates to your due diligence system for 5 years from their occurrence. This includes all records, measures and procedures you have undertaken to ensure compliance with EUDR’s due diligence requirements.
To maintain a due diligence system, you will need to:
- Gather information on your commodity or product via the collection of information, data and documents.
- Conduct a risk assessment by checking whether there is a risk that the commodities or products you intend to place on the market or export are non-compliant with EUDR.
If the risk of non-compliance is not negligible, you must conduct risk mitigation to ensure that you meet this standard.
If you are a large operator, you must report annually on your due diligence system.
1. Gathering information
There are many different means that operators can use to collect information: some have the ability to directly map their suppliers, while others may rely on intermediaries like cooperatives, certification bodies, national traceability systems or other companies.
There is growing awareness of the requirements of EUDR, and therefore producers and suppliers in third countries are increasingly providing the relevant information, particularly the geolocation information, as standard. You may wish to confirm with your suppliers that this information will be available to you before making a purchase.
Certification and third-party verified schemes can play an important role in promoting sustainable agricultural and forestry practices and responsible sourcing, in fostering supply chain transparency and in facilitating compliance with EUDR.
If you are an operator or MSPO, you will need to collect and hold the following information.
To find the information, you can:
- ask your suppliers directly – you may want to do this before purchasing an in-scope product or commodity
- use cooperatives, certification bodies, national traceability systems or other companies
Description of the product
You must collect a description of the relevant products, including:
- the trade name
- the type of product
- a list of the relevant commodities or products used to make, or contained in, the product – for example, ‘reusable coffee pods’, ‘milk chocolate containing cocoa’
If you are placing wood on the Northern Ireland market or exporting wood products from Northern Ireland, you must collect the common name of the wood species and its full scientific name.
Quantity
You must collect the quantity of the relevant products in both:
- kilograms
- any other relevant units – for example, cubic metres for a wood shipment
Country of production
You must collect the country of production and any additional relevant information relating to location. For example, “UK, Scotland, Orkney”.
Traceability data
If you are a MSPO, you can collect either the:
- postal address of all plots of land used for the production of the relevant commodities
- geolocation (latitude and longitude to 6 decimal places) of the plots of land used for the production of the relevant commodities
If you are an operator, other than a MSPO, you must collect the geolocation of all plots where the commodities in the relevant product were produced.
Your obligations differ depending on the plot size where the commodities were produced. If the plot size is:
- under 4 hectares or is a cattle establishment, provide a single centre GPS point sufficient to locate the plot
- 4 hectares and over, collect a polygon map outlining the latitude and longitude of the boundaries of the plot
For cattle-related products, such as beef or live cattle, you must collect geolocation data for all the establishments where the cattle were kept. For example, farms, abattoirs and cattle markets.
Supplier chain details
You must collect the name, address and email address of any business that supplied you with the commodities or products.
Customer details
The name, address and email address of any business to whom you have supplied the commodity or relevant products.
Optional information
You may choose to provide any additional information to help prove that your commodity or product:
- is deforestation-free
- has been produced in accordance with the relevant legislation of the country of origin
Approach in Great Britain
The government has announced its intention to introduce deforestation regulations in Great Britain, meaning if you supply certain forest risk commodities or wood products in Great Britain, you may need to comply with any future deforestation regulations.
The government will soon consult businesses, civil society and international partners on the proposed policy.
We will aim to ensure aspects of the scope and information requirements are broadly the same as those of the EUDR. This is to reduce regulatory divergence between Great Britain and Northern Ireland and support trade with the EU.
For more information, read the UK’s approach to deforestation regulations.
2. Risk assessment
Checking the country or origin’s risk level
You do not need to assess or mitigate risk if your products have both:
- been produced in a country classified by the EU as being at low risk of deforestation
- low risk of having been mixed with products produced in high or standard-risk countries
Check the risk level of your product’s country of origin in the European Commission’s Country Classification List.
The majority of countries are currently categorised as low risk, including the UK, USA, Canada, Australia and India.
Assessing risks
If you are an operator trading in products originating in ‘standard-risk’ or ‘high-risk’ countries, you will need to assess the risk of products to satisfy yourself that there is a negligible risk of those products not complying with EUDR requirements.
Your risk assessment must consider the following criteria found in Article 10 of the EUDR. In practice, therefore, you must consider the following factors in determining that there is a negligible risk of products being non-compliant:
- the rate of forest cover, deforestation and illegal production of the relevant commodity in the country of production
- product-specific risks, including whether the product contains raw materials from multiple geolocations or has undergone substantial chemical or physical processing during manufacture
- the complexity of the supply chain
- any indications that a company within the supply chain has been involved in practices related to illegality, deforestation or forest degradation, noting that commodities or products sourced from such companies may present a higher risk of non-compliance
- any complementary information on EUDR compliance available from certification schemes, third-party verification schemes, or companies within the supply chain
- other country-level risk factors that could affect the reliability of evidence demonstrating compliance with applicable legislation, including levels of corruption, the prevalence of document or data falsification and the effectiveness of law enforcement – relevant indicators, such as corruption indices, business risk assessments, and similar sources of information, may also be taken into account
You should take a proportionate approach to your risk assessment that reflects the:
- complexity of your supply chain
- risk profile of the country of origin for your products
At the end of your assessment, you must conclude that there is a negligible risk that your product is linked to deforestation.
You must review your EUDR risk assessments on at least an annual basis to make sure you are still complying with these rules.
3. Risk mitigation
If your risk assessment shows that there is a non-negligible risk of deforestation, you must take steps to mitigate those risks.
You should again take a proportionate approach to risk mitigation that reflects the:
- complexity and your knowledge of your supply chain
- risk profile of the country of origin for your products
The measures in your risk mitigation must include the following:
- model risk management practices, reporting, record-keeping, or internal control and compliance management
- appointing a compliance officer at management level (if you are not a small or medium-sized enterprise (SME))
The measures in your risk mitigation may also include the following:
- gathering more data, information or documents to check the risk of deforestation – this could involve communicating with others in the supply chain
- carrying out independent surveys or audits
You should document all measures taken to complete your risk mitigation and review them at least annually.
You will need to make them available to the competent authorities on request.
If in-scope products are from a ‘low-risk’ country, you do not need to undertake risk mitigation.
Check the list of what you may include in your risk mitigation in the EU guidance document for EUDR.
Annual reporting
If you are an operator that is not classed as an MSPO, you are required to annually publicly report on your due diligence system. This must contain details of the steps you have taken to comply with these due diligence requirements.
Individuals, MSPOs, SMEs, downstream users and traders do not need to produce this annual report.
Your report must contain:
- a summary of the information you have collated for the ‘Gathering information’ step
- the conclusions of your risk assessment and risk mitigation (if applicable)
- a description of any communications and consultations you have had with relevant people in both the country of origin and of production, such as with indigenous peoples, local communities or other relevant groups (if applicable)
Submitting a due diligence statement (DDS)
As an operator, you will need to complete a due diligence statement (DDS). This is a separate requirement from the gathering of information, risk assessment and, if applicable, risk mitigation which you must also undertake.
You do not need to submit a DDS as a MSPO.
You must submit this before you can place your products on the market in Northern Ireland or export them from Northern Ireland to outside the UK or EU.
If you are an operator in Northern Ireland, you will need to submit a DDS before you make any products available on the EU market.
You must keep a record of each DDS for 5 years from the date of submission in the EUDR information system.
When you must submit a new DDS
You must include a DDS with every shipment.
You can reuse the same DDS for multiple physical batches or shipments, as long as it covers all relevant products. It can cover multiple different relevant products. You can only use a DDS for up to a year after you submit it.
If your DDS covers multiple batches or shipments, you must confirm that due diligence was carried out for all relevant products intended to be placed on the market. Read question 5.19 in the frequently asked questions on EUDR for more details.
How to submit your DDS
You must submit your DDS through the EUDR information system.
The first time you use the system, you will need to create an account. Read the EU guidance on creating an EU login account.
You can download the EUDR user guide for step-by-step instructions on submitting your DDS.
You will be able to manage your due diligence information using the EUDR information system. This includes using the dashboard to view and manage your existing due diligence statements.
If you’re moving a product from Great Britain to Northern Ireland, you will also need to be registered on TRACES NT. This means you will need either an:
- XI Economic Operators Registration and Identification (EORI) number
- EU EORI number
Find out how to get an EORI number.
What to include in your DDS
In your DDS, you must submit the:
- name, address and (if applicable) the EORI number of your business
- the Harmonized System (HS) code of your commodity and/or product
- other specific details about in-scope commodities and products which you’re placing on the market or exporting, such as its description, quantity and the geolocation where it was produced
The following text should also be included in all due diligence statements:
“By submitting this due diligence statement, the operator confirms that due diligence in accordance with Regulation (EU) 2023/1115 was carried out and that no or only a negligible risk was found that the relevant products do not comply with Article 3, point (a) or (b), of that Regulation.”
When you submit your DDS, you will get a reference number. You should retain this for your records and provide it to the downstream operators or traders who purchase the products it covers.
MSPOs: making a one-off simplified declaration
If you are a MSPO, you must make a one-off simplified declaration instead of a DDS.
This must contain:
- your business name and address
- a description and commodity codes for the relevant products you will place on the market
- a one-off estimate of the quantity of each product by volume
- the geolocation or postal address where the products are produced
When you make your declaration, you will receive a declaration identifier. You should retain this for your records and pass it down to the first downstream operator or trader who purchases the products covered by it.
Your declaration identifier provides proof that there was no requirement for your products to be accompanied by a DDS.
If new and relevant information becomes available, you must updated your simplified declaration.
How to submit a simplified declaration statement
You must submit your simplified declaration statement through the EUDR information system.
The first time you use the EUDR information system, you will need to create an account. Read the EU guidance on creating an EU login account.
You are only required to submit this information once unless new information becomes available that requires you to update your statement.
Downstream operators and traders: completing due diligence
If you are a trader or downstream operator that is not an SME, you must register in the EUDR information system.
The first time you use the EUDR information system, you will need to create an account. Read the EU guidance on creating an EU login account.
You can download the EUDR user guide for step-by-step instructions on submitting your DDS.
You must keep records of the suppliers you receive relevant products from and the commercial customers you supply them to. This includes their contact details and, where applicable, the DDS reference number or declaration identifier.
If this information is not provided by your upstream supplier, it may be that you are not the first downstream operator. If your supplier is an operator, you must collect and record the DDS reference number or declaration identifier from them. If your supplier is not the operator, you do not need to actively request a DDS reference number. If you are unsure whether your supplier is an operator, you should check with them.
You must keep these records for at least 5 years and make them available to competent authorities on request.
If you are a downstream operator exporting a relevant product, you do not need to provide a reference number or declaration identifier to customs authorities at export. Instead, you can use a dedicated TARIC certificate code, which exempts downstream operators from providing reference numbers or declaration identifiers.
If you have more than one role
In some cases, you may perform more than one role in the supply chain.
For example, a Northern Ireland shop may purchase coffee beans from a merchant in Great Britain and sell those coffee beans in their shop. This makes the Northern Ireland shop an operator for those coffee beans.
That same shop may also source roasted cacao beans from a wholesaler in Northern Ireland and sell those cacao beans in their shop. The shop is therefore a trader for those cacao beans. The shop must complete the obligations of an operator for the coffee beans, and only the obligations of a trader for the cacao beans.
Moving in-scope products from Great Britain to Northern Ireland
Great Britain to Northern Ireland business to business movements
If you send relevant products from Great Britain to a commercial customer in Northern Ireland, that customer will usually need information from you to help them meet their EUDR obligations.
This may include information such as the geolocation of the plots of land where the relevant commodities were produced.
To support your Northern Ireland customers, you should gather and keep the information needed for them to comply with EUDR. You should clearly identify which of your products are EUDR-compliant so that customers can make informed purchasing decisions.
When an order is placed, you should seek to automate the sharing of the information your customer needs to complete a due diligence statement. If automation is not possible, you should have a process in place that allows your Northern Ireland customer to access the information they need quickly.
Check the obligations for Northern Ireland operators in the ‘Operators: completing due diligence’ section.
Using movement schemes
If your business sends in-scope products from Great Britain to a business in Northern Ireland, the facilitations for declaring products as ‘not at risk’ of entering the EU under the Windsor Framework are unaffected.
You can continue to use the Northern Ireland Retail Movement Scheme (NIRMS).
For movements of in-scope products ’at risk’ of entering the EU, you will need to provide the DDS reference number or declaration identifier as part of your Internal Market Movement Information (IMMI) or customs declaration.
You can also continue to use the IMMI and your Trader Goods Profile (TGP) to automatically populate relevant information.
We will publish further guidance on moving EUDR-regulated products using these schemes.
Great Britain to Northern Ireland business to consumer movements
If you send eligible products from Great Britain to a consumer in Northern Ireland, you can continue to move them under the UK Carrier Scheme (UKC).
This means that, when your goods are moved by an authorised carrier, they can do so without a:
- customs declaration
- duty declaration
- safety and security declaration
Further technical instructions will be provided shortly.
Re-importing products that were previously placed on the EU or Northern Ireland market
If a product has already been on the EU or Northern Ireland market before it entered the Great Britain market, you do not need to submit a new DDS to move it back into Northern Ireland.
You can provide either:
- the DDS reference number or declaration identifier received from your supplier when moving the product into Northern Ireland
- a conventional reference number, if your supplier did not provide you with a DDS reference number or declaration identifier
Further guidance will be provided on this shortly.
Instead of being an ‘operator’ under EUDR, in these circumstances you will be a ‘downstream operator’. Your obligations will be limited to verifying and, if requested, providing evidence to competent authorities that the product was previously placed on, and then exported from, the EU market.
Northern Ireland to Great Britain movements
If you move products from Northern Ireland to Great Britain, you do not need to meet any EUDR requirements.
Qualifying Northern Ireland EUDR products will retain unfettered access to the UK internal market.
Moving products from rest of world (RoW) to Northern Ireland
Rest of world to Northern Ireland business to business movements
If you send in-scope products from outside the UK and EU to a business in Northern Ireland, you must provide the due diligence statement reference number for those products in the customs declaration.
Rest of world to Northern Ireland business to consumer movements
If you send in-scope products from outside the UK and EU to a consumer in Northern Ireland, you must provide the DDS reference number:
- in the customs declaration submitted to HMRC through the Customs Declaration Service (CDS)
- to the express operator who will complete the customs processes as part of their door-to-door service
Northern Ireland to rest of world (outside the UK and EU)
If your in-scope products are moved from Northern Ireland to the rest of world (outside of the UK and EU), you must provide the DDS reference number on the export declaration.
Get help with EUDR
If you have questions about this guidance or your obligations under EUDR, contact frcregulations@defra.gov.uk