What a breach can cost, how inspections are chosen and what an audit trail must hold. The penalties are set by Member States within a common frame.
Summary
Article 25 obliges Member States to lay down effective, proportionate and dissuasive penalties. The Regulation sets a floor for the maximum fine: it must be at least 4 % of the annual Union-wide turnover of the operator or trader. National law decides the rest.
The penalties go beyond fines. Products and the revenue gained from them can be confiscated, the company can be excluded from public procurement and public funding for up to twelve months, and placing on the market, making available or export can be prohibited for a time.
The best protection is a record that can be produced on request. Keep the statement, the plot data, the risk assessment and the supplier documents for five years, and be able to show them in one place.
Fines of up to at least 4 % of EU turnover
The maximum fine laid down in national law must be at least 4 % of the annual Union-wide turnover. It is a ceiling, not a tariff: authorities set the actual amount by the gravity of the breach, its duration, repetition and the cooperation of the company. We have not checked the national rules of Croatia or Slovenia.
A company that has no activity in the Union but exports into it is judged by its Union-wide turnover. For a small exporter the fine can be small in absolute terms, but exclusion from the market is often the larger loss.
Confiscation, public procurement exclusion and market bans
Confiscation reaches the goods and the money they earned. A company that supplies public buyers can be shut out for up to twelve months, which can matter more than the fine itself. A temporary ban stops placing on the market, making available and export of the products concerned.
How inspections are chosen
Competent authorities draw up annual plans and check on a risk basis. Article 16(8) to (10) sets minimum annual levels: 9 % of operators and of the quantity for high-risk countries, 3 % of operators for standard-risk and 1 % for low-risk countries. The risk criteria also weigh the commodity, the length of the supply chain and the history of breaches of the Regulation (Article 16(3)).
Authorities can also act on a substantiated concern raised by a third party. A flagged plot in your records that you did not follow up is the situation that does most damage in an inspection.
Need to verify your EUDR compliance?
We check your tariff codes, plot geolocation and batch traceability against the EUDR obligations, and prepare the due diligence statement for you. Send us your product and supplier list and we will tell you where the gaps are.
The audit trail: what it must show
An inspector will ask for the statement, its reference number, the plot geolocation, the risk assessment and how you reached its conclusion, and the supplier evidence. For each sale of the product, they will ask which statement covers it.
In our platform every manual review of a plot is stored in an append-only log: who changed what, from which status to which, with a written note. The submitted package is stored with a SHA-256 fingerprint. These practices are ours, and the Regulation does not mandate them, but they make the five-year record easy to produce.
Five-year retention and preparing for an inspection
The record of the statement is kept for five years from submission (Article 4(3)), and the information collected under Article 9(1) for five years from placing on the market or export. Prepare a folder per statement with the package, the plot data, the assessment, the supplier documents and the sales that used the reference number.
Run a mock inspection once a year. Pick three statements at random and try to produce the full record within a day. Every gap you find is a gap an inspector would find.
Penalties and checks at a glance
| Article | Measure | Applies to | Date rule |
|---|---|---|---|
| 25 | Fine with a maximum of at least 4 % of annual Union-wide turnover. | Operators and traders | From the application date that applies to the company. |
| 25 | Confiscation of products and revenue; exclusion from public procurement and funding for up to 12 months. | Operators and traders | From the application date that applies to the company. |
| 25 | Temporary prohibition of placing on the market, making available or export and, for serious or repeated infringements, loss of the right to simplified due diligence. | Operators and traders | From the application date that applies to the company. |
| 16(8)-(10) | Risk-based checks with minimum shares of 9 %, 3 % and 1 %. | Operators and traders | From the application date that applies to the company. |
| 4, 9 | Keep the statement and supporting information for five years. | Operators | From the application date that applies to the company. |
HS/CN codes and records to hold
| Commodity | HS/CN heading | Records an inspector asks for | Retention |
|---|---|---|---|
| Wood and paper | HS 44, 48, 4819 | Statement, polygons, mill and supplier documents, bill of materials | 5 years |
| Coffee and cocoa | HS 0901, 1801 | Statement, farm polygons or points, cooperative records | 5 years |
| Natural rubber | HS 4001 | Statement, plantation polygons, purchase records | 5 years |
| Bovine meat | HS 0201 | Statement, establishment locations, animal movement records | 5 years |
Exemptions
The penalty provisions have no exemptions by size. The simplified regimes change only the amount of work.
- Micro and small primary operators file a simplified declaration, but they remain subject to checks and penalties.
Frequently asked questions
How high can EUDR fines be?
Member States set them; the maximum fine must be at least 4 % of annual Union-wide turnover. Products and revenue can be confiscated and public procurement can be closed for up to 12 months.
How often do authorities check operators?
Minimum annual levels are 9 % of operators and of the quantity for high-risk countries, 3 % of operators for standard-risk and 1 % for low-risk countries (Article 16(8) to (10)).
Book a 15-minute EUDR audit
We look at your product list, tariff codes and plot data and tell you where the gaps are. Write to us through the contact page; a booking slot is offered here when it is available.
Sources
- Regulation (EU) 2023/1115 of the European Parliament and of the Council of 31 May 2023 on deforestation-free products (EUDR), OJ L 150, 9.6.2023. Read in the Official Journal text on 10 November 2026.
- Regulation (EU) 2025/2650 amending Regulation (EU) 2023/1115 (application dates, downstream operators, simplified declaration, scope). Read in the Official Journal text on 10 November 2026.
Facts last checked against the Official Journal text on 10 November 2026.
This page is general information, not legal advice. It reflects the Official Journal text of Regulation (EU) 2023/1115 as amended and Commission guidance as read on 10 November 2026; items marked as expected are not confirmed. Obligations depend on your role, product and Member State. Check the current official text on EUR-Lex.