EUDR Transitional Period: What EU Importers and Non-EU Exporters Need to Know

EUDR transitional period is the window between the Regulation’s entry into force on 29 June 2023 and its entry into application 30 December 2026 for large and medium companies, and 30 June 2027 for micro and small operators. Relevant commodities and products placed on the EU market during this window are exempt from due diligence, but downstream operators and traders who later place derived products on the market must hold adequately conclusive and verifiable evidence that the input was placed on the EU market before the applicable application date.

Key takeaways

• The EUDR transitional period runs from 29 June 2023 to the day before entry into application (FAQ 9.5).
• Application dates: 30 December 2026 for large/medium operators and traders; 30 June 2027 for micro and small undertakings and natural persons.
• No due diligence statement (DDS) is required for stock placed on the market during the EUDR transitional period; obligations shrink to holding evidence of the placing date.
• Downstream operators and traders must prove the input was placed on the EU market before the application date the burden of proof sits with the operator.
• Transition stock and compliant stock can be mixed if every batch is traceable to one bucket or the other and all Article 3 conditions are met.
• Timber and timber products carry a special carve-out under Art. 37(2) treat them separately.

What the EUDR transitional period means for importers and exporters

EUDR transitional period is the single most misread part of the Regulation for teams sitting on inventory today. The confusion is expensive: a coffee importer, a tyre manufacturer or a chocolate maker with warehouses full of stock bought in 2024 or 2025 needs to know, batch by batch, which goods are grandfathered and which will need a full due diligence statement once enforcement begins. Guess wrong and you either file DDSs you never needed, or you place non-exempt product and expose the business to interim measures, seized shipments and fines of up to 4% of EU-wide turnover.

The good news is that the Commission’s own FAQ (Version 5, April 2026) is unusually concrete about how the EUDR transitional period works in practice. Section 9 walks through the exact scenarios most buyers face rubber into tyres, cocoa butter into chocolate, a trader onselling old stock and spells out the evidence that keeps that stock legally on the market. This guide turns those provisions into a decision you can actually operationalise.

EUDR transitional period timeline: entry into force to entry into application

In plain terms, the EUDR transitional period is a grandfathering window. The Regulation entered into force on 29 June 2023, but its substantive obligations only start to apply later. Anything lawfully placed on the EU market inside that window does not have to meet the deforestation-free, legality and DDS requirements of Article 3.

Two application dates close the window, depending on who first placed the goods:

• 30 December 2026 — for large and medium operators and traders (42 months after entry into force).
• 30 June 2027 — for micro and small undertakings and natural persons acting as operators (48 months after entry into force).

Because the deferred date exists, the EUDR transitional period effectively ends on a different day for different supply chains. If your input came from a micro or small operator, the relevant cut-off for that input is 30 June 2027, not 30 December 2026 a distinction that changes which of your goods are exempt.

EUDR transitional period scenarios: worked examples from the Commission FAQ

The clearest way to apply the EUDR transitional period is through the Commission’s own worked examples. In each, note the pattern: once a relevant input was placed on the market during the window, the downstream company’s job is not full due diligence it is proving the placing date.

Scenario 1 — Natural rubber into new tyres

Natural rubber (CN 4001) is placed on the EU market during the EUDR transitional period, so it was never geolocated. From 30 December 2026, a manufacturer turns that rubber into new tyres (CN 4011) and places them on the market. The downstream operator’s obligation is limited to gathering adequately conclusive and verifiable evidence that the rubber was placed on the EU market before entry into application. No DDS for the rubber is required. If, however, part of the rubber was placed from 30 December 2026 onward, that portion falls under the standard obligations.

Scenario 2 — Cocoa butter into chocolate

Cocoa butter (CN 1804) is placed on the market during the EUDR transitional period, then used to make chocolate (CN 1806) placed on the market by a downstream operator from 30 December 2026. Again, obligations are limited to evidence that the cocoa butter was placed before the application date. Any component made with cocoa placed from 30 December 2026 onward is subject to the full Regulation.

Scenario 3 — A trader onselling transition stock

An operator places a commodity or product during the EUDR transitional period; one or more traders then make it available on the market from 30 December 2026. The traders (and any subsequent downstream operators and traders) only need adequately conclusive and verifiable evidence that the goods were placed before entry into application.

Scenario 4 — Inputs from a micro or small operator (deferred date)

A downstream company places a product made from a commodity that a natural person, micro or small operator placed on the market before 30 June 2027. Here the EUDR transitional period reference date is the deferred 30 June 2027 cut-off, and the downstream company’s obligation is limited to evidencing that earlier placing.

Your HSN/HS code can determine whether a product falls within the scope of EUDR—but getting the classification wrong can create compliance gaps.

Read our guide on EUDR HSN/HS Codes to understand how product classification works, which codes are relevant, and how to determine whether your products require EUDR due diligence.

EUDR transitional period evidence: what proof you must keep

The whole benefit of the EUDR transitional period depends on documentation. The operator bears the burden of proof that goods were placed on the EU market before the application date, and no due diligence statement is filed for that stock. Competent Authorities can check transition claims at any time, so the evidence has to be linkable to the specific product.

For imported goods, the customs declaration is the accepted evidence of placing on the EU market. For EU-produced goods and for supporting the placing date generally, the FAQ accepts:

• Felling tickets, ear tags and cattle passports, invoices, and other production- or selling-date records
• Contracts between the parties and product order documents
• Shipment documents: CMRs, bills of lading, delivery notes and air-waybills

For export or re-import of transition stock, a conventional DDS reference number the universal placeholder 99EU9999999999 can be entered on the customs declaration. Where a downstream operator exports, no reference number is needed at all; a dedicated TARIC certificate code is used instead.

EUDR transitional period and mixing: combining transition stock with compliant stock

A recurring buyer question about the EUDR transitional period is whether old and new stock can sit in the same silo, tank or pallet. The answer is yes provided every batch is proven to be either transition stock (with evidence of placing during the window) or fully compliant stock, and all Article 3(a)–(c) conditions are met for the compliant portion.

Inside the Information System, only the post-transition stock is declared. When you mix grandfathered commodities with newer stock, the DDS covers just the newly placed quantities that are actually subject to due diligence the transition portion stays off the system, backed by your evidence file.

Most teams treat the EUDR transitional period as a one-off amnesty and under-invest in record-keeping then scramble when a Competent Authority asks for proof two years later. The smarter play is to treat transition evidence as the first entry in the same data layer you will use for live DDS filings. TraceX tags each batch as transition-exempt or in-scope, stores the placing-date evidence against it, and carries that classification through mixing and processing steps so the exemption is defensible on demand rather than reconstructed under pressure.

EUDR transitional period vs standard obligations: a side-by-side

This table summarises how obligations differ between goods placed during the EUDR transitional period and goods placed after entry into application.

EUDR transitional period done right: fewer stranded shipments, cleaner audits

Handled well, the EUDR transitional period protects working capital. Every batch you can legitimately classify as transition-exempt is a batch you don’t have to geolocate, risk-assess or block at the border while every batch you can’t evidence is a liability waiting for a check. The dividing line is your documentation, not your intentions.

How TraceX Cleara AI supports transition-period classification

TraceX EUDR Solutions is built for EUDR specifically and lets compliance teams flag transition stock, attach placing-date evidence customs declarations, invoices, CMRs, felling tickets at the batch level, and preserve that status through mixing and manufacturing.] [It then generates and files DDSs only for the in-scope quantities], which is exactly the split the Commission describes for mixed stock in the Information System. All product-capability statements here are bracketed for product-team sign-off before publication.

EUDR transitional period compliance checklist for buyers

Use this checklist when evaluating whether your process or a vendor’s platform can defend a EUDR transitional period claim under audit:

• Batch-level classification: Can every SKU or lot be tagged transition-exempt or in-scope, and re-checked against the correct cut-off date (30 Dec 2026 or 30 Jun 2027)?
• Evidence capture: Does the system store customs declarations, invoices, contracts, CMRs, bills of lading and cattle documents against the specific batch?
• Mixing integrity: When transition and compliant stock combine, does the tool keep each batch traceable and file a DDS for only the in-scope quantity?
• Customs handling: Can it apply the conventional reference number 99EU9999999999 or the downstream-export TARIC code correctly?
• Timber carve-out: Does it treat timber and timber products under Art. 37(2) separately from other commodities?
• Audit readiness: Can you retrieve the full evidence trail for a Competent Authority check within a reasonable period?

Frequently Asked Questions (FAQ’s)