DECISION BRIEF
What the rule requires
Regulation (EU) 2023/1115 allows cattle, wood, cocoa, soy, oil palm, coffee and rubber — and derived products including leather, chocolate, tyres and furniture — to be placed on or exported from the EU market only if they are deforestation-free, produced in accordance with the law of the producing country, and covered by a due diligence statement.
Regulation (EU) 2025/2650, published on 23 December 2025 and in force since 26 December 2025, postponed and simplified it. The regulation applies to large and medium operators and traders from 30 December 2026, and to micro and small operators from 30 June 2027. Only the operator that first places a relevant product on the EU market submits the due diligence statement; micro and small primary operators submit a one-off simplified declaration.
Who is affected, and from when
Built for: Exporters of furniture, wood and paper packaging, leather goods and footwear, tyres and rubber products, and cocoa and coffee derivatives, plus their procurement teams.
Turkish suppliers are not operators under the regulation. The EU importer is. But the importer cannot file a due diligence statement without plot geolocation, production or harvest dates, supplier identity and evidence of legality — and all of that has to come up the chain from you.
The commodity list is wider than it looks from the headline. Leather in automotive interiors and footwear, rubber in tyres and components, wood in furniture and in the pallets and packaging around an unrelated export: each is a route into scope.
The operative date for most Turkish supply relationships is 30 December 2026, because the EU counterparties are large and medium operators.
What to do next
- Map which of your SKUs contain any of the seven commodities, including the packaging and pallets you ship on.
- Start collecting geolocation of the plots of land your raw material came from now — this is the data that does not exist yet in most Turkish supply chains and takes the longest to build.
- Keep legality evidence under producing-country law with the consignment documentation, not in a separate folder nobody can find.
- Agree in writing with each EU buyer who submits the due diligence statement and what you are contractually required to supply, before the first order after the date.
Coverage boundary
This is the EU regulation and the Turkish supplier’s side of it. Net Zero does not track national forestry law here, and coverage of this subject is currently thin — what we have is listed below and nothing is padded.