July 2026: Full EUDR Enforcement Begins and Every Amazon SKU May Need Traceability
At midnight on 30 June 2026, the transition period for smaller businesses under the EU Deforestation Regulation, Regulation (EU) 2023/1115, ended. From 1 July 2026, products in the seven covered commodity groups entering the EU market need to follow the full due diligence process regardless of company size. For Amazon cross-border sellers, this is no longer an early warning. It is an active compliance requirement.
What Does EUDR Cover?
EUDR aims to prevent commodities and relevant products linked to deforestation or forest degradation from being placed on, made available on, or exported from the EU market. Goods produced on land subject to deforestation after 31 December 2020 are not eligible for the EU market.
The regulation covers seven core commodity groups and many derived products: cattle, cocoa, coffee, oil palm, rubber, soy, and wood. For Amazon sellers, the impact can extend to wooden furniture, paper products, leather goods, rubber products, cosmetics containing palm derivatives, food products, and packaging or product components linked to covered commodities.
The Four-Step Due Diligence Process
EUDR cannot be solved by a simple declaration or a single certificate. Operators and traders need a complete due diligence workflow.
Step 1: Information Collection
Collect product description, commodity type, quantity, supplier details, country of production, geolocation data, production plot information, and evidence showing the product is deforestation-free and produced in accordance with the relevant laws of the country of production.
Step 2: Risk Assessment
- Assess the country risk classification and the actual production area risk.
- Check whether production occurred on land deforested after the 31 December 2020 cutoff date.
- Review supply chain complexity and transparency.
- Consider corruption, weak enforcement, legal gaps, and indigenous land rights issues where relevant.
Step 3: Risk Mitigation
If risk signals are found, sellers may need supplementary supplier evidence, independent third-party audits, on-site checks, supplier changes, or origin changes before placing goods on the EU market.
Step 4: Due Diligence Statement Submission
After completing the preceding steps, submit the Due Diligence Statement through the EUDR Information System and obtain a reference number. This number needs to travel with the goods so customs and market surveillance authorities can verify the shipment.
What Changed From 1 July 2026?
From July 2026, EUDR applies fully to all covered goods entering the EU market regardless of business size. The previous observation window for smaller businesses has closed, and sellers should assume customs, market regulators, platforms, and larger buyers may request traceability evidence.
The Cost of Non-Compliance: Fines, Market Access Risk, and Shipment Disruption
EUDR enforcement is carried out by EU Member State customs and market surveillance authorities, not only by Amazon. Even if the marketplace has not yet requested every document, non-compliant goods can still face checks at ports, detention, penalties, product withdrawal, or restrictions on EU market access.
High-Risk Amazon Seller Category Checklist
Review products that may contain wood, paper, leather, rubber, soy derivatives, palm oil derivatives, cocoa, coffee, or cattle-related materials. Prioritize high-revenue ASINs, products shipped into Amazon EU fulfillment channels, and items with complex upstream supply chains.
Seller Roadmap: Four Tasks to Complete in Q3 2026
July: SKU Inventory and Risk Classification
- Export all Amazon EU SKUs and map them against the seven commodity groups and relevant product lists.
- Mark directly covered SKUs, such as wooden furniture, and indirectly exposed SKUs, such as cosmetics containing palm oil derivatives.
- Prioritize core SKUs that contribute the largest share of revenue.
August: Supply Chain Traceability Start
- Contact upstream suppliers and request origin information and GPS or plot-level geolocation data.
- Evaluate supplier cooperation. Suppliers able to provide precise traceability data should be prioritized.
- Collect supporting evidence such as RSPO certification for palm-related materials, FSC certification for wood, third-party audit reports, or satellite monitoring records where applicable.
September: Risk Assessment and System Registration
- Complete risk assessment and mitigation under the due diligence process.
- Register in the EUDR Information System and prepare Due Diligence Statement submissions.
- Build an internal mapping between statement numbers, products, shipments, and customs documents.
Ongoing: Supply Chain Compliance Maintenance
- Set up at least annual due diligence reviews.
- Monitor changes in country risk classification and supplier sourcing changes.
FAQ
Q1: I am a trading seller sourcing from a Chinese factory and shipping to FBA. Do I need EUDR compliance?
Yes, if you place covered goods on the EU market as the operator. If an EU importer places the goods on the market, that importer may hold the primary operator obligation, but the seller still needs to provide supply chain data.
Q2: Does a product paper box trigger EUDR?
It depends on whether the paper box is part of the product sold to the consumer and whether it falls within relevant product scope. Pure transport packaging may be treated differently, but sellers should still include packaging materials in traceability checks to reduce risk.
Q3: Can FSC certification replace EUDR compliance?
No. FSC certification can be useful evidence, but it does not replace EUDR due diligence. EUDR requires geolocation, risk assessment, mitigation where needed, and due diligence statement submission.
Q4: What about inventory already in an EU warehouse?
Enforcement details can vary by Member State and shipment status. For high-value or high-volume FBA inventory, sellers should complete traceability files as soon as possible instead of relying on uncertainty.
Q5: Will enforcement immediately become strict after the transition period?
Implementation may include an education or warning period in some contexts, but that should not be treated as permission to delay. Customs capability, buyer requirements, and supply chain pressure can increase quickly after the first enforcement cases.
July Has Arrived: EUDR Requires Traceable Supply Chains
EUDR is one of the EU Green Deal regulations with the deepest supply chain reach. It changes not only raw material trade, but also the compliance baseline for consumer product sellers selling into Europe.
Early preparation can help sellers build a defensible supply chain file. Delayed preparation can create customs, platform, and buyer-side risks during peak sales periods.
Contact GreenArk
GreenArk (Shenzhen) Certification Co., Ltd. / 绿色方舟（深圳）认证有限公司 provides EUDR compliance support for Amazon cross-border sellers, including:
- SKU risk diagnosis and EUDR applicability assessment.
- Supplier traceability guidance and data collection templates.
- Due diligence workflow support from information collection to risk mitigation and statement preparation.
- EUDR Information System registration and submission support.
- Ongoing compliance maintenance, annual review reminders, and supplier change checks.
We do not create panic. We provide workable compliance paths.
Email: sui@greenark-sz.com
Website: www.greenark-sz.com
Phone / WeChat: 18407559004
This article is prepared by GreenArk (Shenzhen) Certification Co., Ltd. / 绿色方舟（深圳）认证有限公司 based on public EUDR materials available as of July 2026. Specific obligations should be confirmed against the official EU text, Commission guidance, and Member State enforcement rules.
