Is your product ready for EUDR?
EUDR (Regulation (EU) 2023/1115) directly affects manufacturers shipping wood, paper and board, furniture, pallets, cocoa, coffee, rubber, soy, palm oil and cattle products to the EU. From 30 December 2026 your EU customer will ask you for plot geolocation and legality evidence. Start with the free EUDR Scope Check.
Türkiye is classified low risk. But where does your imported raw material come from?
Measurable EUDR readiness on the supplier side
Regulation (EU) 2023/1115 · as amended by 2025/2650 · the application date depends on the operator's scale; for a Turkish supplier, 30 December 2026 applies in practice
Some of the conditions your supply chain has to meet (Regulation (EU) 2023/1115)
The plot the raw material comes from must not have been converted from forest to agricultural use after this date. For wood, forest degradation is an additional criterion. What counts is the date of land-use change, not the purchase date.
Coordinates of every production plot, at least 6 decimal places (WGS-84). Polygons are mandatory above 4 hectares; a single point is enough below. Declarations by region or country are not allowed.
A due diligence statement (DDS) reference number is entered on the customs declaration for every placing on the EU market. Article 9 information is kept for 5 years. Penalties: fines of at least up to 4% of EU turnover, confiscation, market ban.
Scope is decided by customs tariff code, not by product name
Only codes listed in Annex I are in scope. Commodities produced in Türkiye may use the simplified regime (Art. 13); imported raw material carries the risk class of its country of origin.
* Commission draft delegated act (May 2026): instant coffee and some palm derivatives added; leather and retreaded tyres removed; packaging, samples, waste and second-hand goods exempt. Until adopted, the current Annex I applies.
The obligation sits with the importer, the data sits with you
Your customer has started asking
From 30 December 2026 the EU operator needs plot geolocation, harvest period and legality evidence from its supplier to submit a DDS. A supplier that cannot deliver drops off the list; the importer takes the penalty, you lose the order.
Türkiye is low risk, your raw material may not be
Implementing Regulation 2025/1093 classifies Türkiye as low risk; simplified due diligence suffices for wood produced in Türkiye. Brazilian coffee, Ivorian cocoa or Ukrainian timber are standard risk; Russia and Belarus are high risk: full regime, 14-criteria risk assessment and checks on up to 9% of operators.
No third postponement
The regulation was postponed twice (2024/3234, 2025/2650). In its May 2026 simplification package the Commission stated there will be no third extension. The Information System is open, the country list is published, the guidance is in its 3rd edition. Preparation time runs to the end of 2026.
Four steps from check to delivery
Free Scope Check
Preliminary indicator and PDF report in 3 minutes, based on HS code, role, country of origin and company size.
Free preliminary assessment
Our team reviews the customs declaration, product list and supplier structure; determines your role (A / B / B+) and a prioritised roadmap.
Detailed offer
Fixed price, fixed timeline. Diagnosis, set-up and ongoing items quoted separately.
Compliance delivered
Supplier data pack, geolocation file, legality evidence set, risk assessment; in scenario B, DDS and Information System registration.
Three entry points
EUDR Scope Check
Automated, 3 minutes, PDF. Are you in scope, what is your role, which date binds you, which regime applies: the first answer.
Compliance Service
11-stage roadmap: role determination, scope matrix, chain mapping, geolocation pipeline, segregation, Article 9 file, risk regime, supplier contract, corporate system.
Geolocation & Plot Verification
We convert supplier coordinates to GeoJSON, check them against 2020 forest cover and post-2020 change maps, and report inconsistencies.
A defined deliverable for every stage
Scope and Role Determination Free preliminary assessment
Role by the importer field of the customs declaration (A: supplier, B: EU subsidiary as operator, B+: you import yourself); scope matrix by product code; share of EU turnover in and out of scope.
Geolocation Pipeline and Verification Set-up
Collecting plot coordinates, converting to GeoJSON/WGS-84, applying the 4 ha rule, checking against open-source maps based on EUFO 2020 and Copernicus, inconsistency report.
Supplier EUDR Data Pack Deliverable
The Article 9 set that goes straight into your EU importer's DDS: product description, quantity, country of production, geolocation and harvest period, parties, deforestation-free and legality evidence. TR/EN, in the importer's format.
Legality File Set-up
For Turkish-origin wood: OGM sales documents and forest-product transport permits, private forest and afforestation permits, land-use rights; for imported raw material: the eight-heading legality evidence set of the country of origin and document reliability assessment.
Origin Risk Assessment and Mitigation Set-up
Regime selection by country class (Art. 13 simplified / Art. 10–11 full); 14-criteria assessment; mixing and mass-balance checks; mitigation through additional documents, audits or supplier change.
DDS, Information System and Supplier Contract Set-up · Ongoing
In scenario B/B+: Information System registration, DDS submission and grouping support; in scenario A: supplier data request and contract clauses (format, deadline, accuracy warranty, audit right), annual review and substantiated-concern response.
The data you collect for EUDR also feeds PPWR and CSRD
A data model built by plot, supplier and product code is not for one regulation. The same wooden pallet is packaging under PPWR and a product under EUDR; the same supply chain is a line in your CSRD report. We build the data once, in an auditable form.
ME Geo is a service line of Marine Emission. Marine Emission provides compliance services to Turkish companies across the full range of EU sustainability and environmental legislation (from maritime emissions reporting to the carbon border adjustment, from packaging to deforestation) and has worked with competent authorities and verifiers in all 27 EU member states and on compliance projects at more than 30 industrial companies.
Content is advisory and not binding legal advice. The authority and responsibility to declare conformity rest with the operator.
Short answers
What is EUDR?
The EU Deforestation Regulation (Regulation (EU) 2023/1115). Seven commodities (cattle, cocoa, coffee, palm oil, rubber, soya, wood) and the derived products listed in Annex I may be placed on the EU market only under three conditions: deforestation-free after 31 December 2020, produced in accordance with the legislation of the country of production, and covered by a due diligence statement.
When does it apply?
The application date depends on the operator's scale. It is 30 December 2026 when the operator is medium or large, when the scale is unknown, or in the timber sector; 30 June 2027 for a micro or small operator outside the timber sector. In scenario A the operator is the EU importer. For a Turkish supplier, 30 December 2026 applies in practice. In its May 2026 simplification package the Commission stated there will be no third postponement.
Türkiye is low risk. Do I still need to do anything?
Yes. Low risk does not remove due diligence, it simplifies it: geolocation, legality evidence and the declaration are still required; only the risk assessment and mitigation steps (Art. 10–11) are skipped. The simplification also requires that all relevant commodities in the product were produced in low-risk countries. If you use imported cocoa, coffee or timber, the full regime applies to that item.
Am I the operator, or is my EU customer?
Whoever is named in the importer field of the customs declaration is the operator; delivery terms (Incoterms) are not decisive. In a typical export the EU buyer is the operator and you are a third-country supplier: you do not submit a DDS, but you provide all the data the importer's DDS rests on. If your EU subsidiary imports, the subsidiary is the operator; if you import in your own name, you become an operator too.
How do I collect geolocation data, and what if I don't have it?
The data originates where you buy the raw material: in Türkiye the OGM sale or private-forest plot/compartment; for imports, the trader or cooperative layer. Data format, deadline and accuracy warranty go into the supplier contract. Coordinates are checked against open-source 2020 forest-cover and post-2020 change maps; these maps are not binding but flag risk. If the data cannot be obtained at all, that raw material cannot go into EU-bound product.
Are wooden pallets and packaging in scope?
Pallets sold as a product (HS 4415) are in scope. Packaging and pallets used to carry or protect another product have been out of scope from the start; the May 2026 draft delegated act writes this as an explicit exemption. PPWR packaging obligations apply separately to the same pallet.
Where should we start?
With scope and role determination. The distribution of your product codes across Annex I and the importer field on your customs declaration decide the size of the compliance burden and which stages apply to you. The free Scope Check gives a first answer to both; the preliminary assessment confirms it.
Let's assess your supply chain together
Your product list and a sample customs declaration are enough. The preliminary assessment is free.