must my foreign company also comply with the deforestation regulation
Yes, the EUDR applies outside the EU as well
Yes: the deforestation regulation looks at what enters the EU market, not where a company is established. A company outside the EU that places coffee, cocoa, wood, rubber, soy, palm oil or cattle (or products thereof) on the European market is subject to the same obligations as a European company that does so. The company's place of establishment is not the determining factor; the question is whether the product enters the EU market or is exported from the EU.
In practice, this often happens through an importer or representative in the EU, and that changes the distribution of the obligation. Whoever first places a product on the EU market is generally considered an operator with the associated heavier obligations; whoever only resells within the EU what is already on the market usually falls under the lighter position of trader. Which of the two applies and what that concretely means is described on Am I an operator or trader under the EUDR?. For a company outside the EU that sells through a European party, it is also good to know that the entry date is not separate from the role; which date applies depends on the combination of role and product, as explained on When does the deforestation regulation apply to my business?.
Where this follows from the regulation
Regulation (EU) 2023/1115 defines the scope via the "placing on the market" and "making available on the market" of relevant products, and not via the place of establishment of the company; whoever offers those products, regardless of origin, on the EU market falls under the definitions of operator or trader as set out in that regulation. Regulation (EU) 2025/2650 amends the timeframes and simplifies certain obligations, but does not change this starting point. The precise definitions and the full text are on EUR-Lex at Regulation (EU) 2023/1115.
What this is based on
- Regulation (EU) 2023/1115 (deforestation regulation)
- Regulation (EU) 2025/2650 (extension and simplification)
- European Commission — deforestation-free products
- Commission — adjustment of the product scope, 13 July 2026
The regulation itself is on EUR-Lex. We reference each statement; you do not need to take our word for it.
What you need to do specifically
The detailed requirements for each obligation, including applicable deadlines and templates for documentation, are included in the subscription.
View the subscription First take the free quick scanThis is not legal advice. This page provides general information about the regulations that this platform covers. We do not know your situation. If you are in doubt about your own case, consult a lawyer or the competent supervisory authority.
Written with AI based on the sources above, checked by a human on 2026-09-05. Is something incorrect? Let us know — corrections are prioritised.