Without a submitted due diligence declaration, a product that falls under the deforestation regulation may not be placed on the EU market or made available on the market. That is the key point: the declaration is not a formality afterwards, but a condition that the regulation links to the moment when you import, trade or export the product.
What happens next in concrete terms depends on where you are in the supply chain and what the competent authority in your Member State establishes. The regulation itself leaves it to the Member States to determine how they sanction breaches; it does not prescribe one fixed amount or one fixed measure. For the precise implementation in your country, we refer you to the official text and to the competent supervisory authority, not to our own assessment.
Why the declaration plays a key role
The due diligence declaration (or the simplified declaration, depending on your role and the risk classification of the country of origin) is the document with which you demonstrate that you have completed the legally required risk assessment. Without that declaration in the EU information system, the evidence that a customs authority or market surveillance authority needs to allow the product through is missing. This makes submitting it practically unavoidable for anyone falling under the regulation, regardless of company size.
Whether and from which date that obligation applies to you depends on your role in the supply chain and the product you trade. If you have not yet clarified this you can check this yourself in a few questions before time pressure builds up.
What can practically go wrong
The most direct consequence occurs at the moment of import or trade itself: without a registered declaration, a consignment can be held up until the missing document is provided. For a coffee roaster who relies on a fixed delivery time, or a timber trader with an ongoing contract, this is the consequence that becomes noticeable first, apart from what a supervisory authority does with it otherwise.
In addition, the supply chain itself acts as a control mechanism. A buyer further down the supply chain often asks for proof that the declaration has been submitted, precisely because that buyer cannot fulfil their own obligation without the data from their suppliers. If that proof is missing, it is not unusual for a business partner to withhold the order or switch to another supplier, even before anything happens on the part of the authorities.
What the regulation says about sanctions
The deforestation regulation leaves the implementation of sanctions to the Member States. This means that the nature and severity of a sanction can vary from country to country, and that we deliberately do not mention here any amounts or measures that we cannot support with the official text. What is certain: the regulation links the absence of a declaration to the prohibition of placing the product on the market, and that link is the starting point that every market participant and trader takes into account.
For the exact wording and the current situation in your Member State, the official regulation text is the point of departure; questions about your own situation belong with a lawyer or the competent supervisory authority, not with a general explanation such as this.
How you prevent it from coming to that
Submitting a declaration is the final piece of a process that begins earlier: mapping suppliers, collecting geodata from plots, checking the risk classification of the country of origin and recording documents that must be kept for five years. If you build that process for each product stream, you will have no rush when it comes time to submit.
On the knowledge base by topic is detailed with what is involved for each commodity and for each role, and an overview of where the information in a file comes from show how that process works in practice. If you have any lingering questions about what specifically applies to your situation, then the overview with frequently asked questions often a faster route than searching through the regulation itself.
Do you first want to know whether and when the obligation to submit applies to you? The free role check provides an indication of that in just a few questions, without you having to set up a file right away.