What Does Deforestation-Free Mean Under EUDR?

The definition has a land condition and a wood condition

Under EUDR, deforestation-free means that relevant products contain, have been fed with or have been made using relevant commodities produced on land not deforested after 31 December 2020. For relevant products containing or made using wood, the wood must additionally have been harvested without inducing the defined forest degradation after that date.

This is a specific legal definition in Article 2(13). It is not simply a general claim that a supplier plants trees, holds a sustainability certificate or produces legally. The production location, land-use history and, for wood, relevant forest transition need to support the conclusion for the actual goods.

The deforestation-free requirement forms one part of Article 3. The current Regulation also requires lawful production and the applicable statement or declaration coverage.

Deforestation means a particular conversion

Article 2(3) defines deforestation as conversion of forest to agricultural use, whether human-induced or not. First determine whether the earlier land met the forest definition. Then establish whether the later use is agricultural. Tree-cover loss is an observation that may indicate such a change, but does not alone answer both legal questions.

For example, clearing qualifying forest for a coffee plantation after the cut-off can fail the land condition even if the new plantation quickly develops dense tree cover. Conversely, a temporary harvest opening in managed forest is not automatically agricultural conversion. Its facts and any wood-specific degradation issue still require assessment.

The forest definition includes area, tree height, canopy cover or capacity to reach the thresholds, and excludes predominantly agricultural or urban land. Use the definitions together rather than selecting whichever map label appears most favourable for the supplier.

What the 2020 date does and does not mean

The cut-off looks backward to changes after 31 December 2020. It is separate from the dates when EUDR obligations apply to businesses and products. A later market application date does not move the land cut-off or permit conversion during the interval before enforcement begins.

Goods produced on agricultural land established before the cut-off may satisfy this particular land-history condition, but that fact alone does not establish full compliance. Check relevant production-country legislation, traceability, risk and the applicable submission regime separately.

Land converted from forest to agriculture after the cut-off does not become acceptable merely because several growing seasons pass. Nor should an operator assume that buying the land from a new owner removes the history. The assessment concerns the production land and relevant commodity, not only the current producer's personal conduct.

Wood needs an additional assessment

For wood-containing relevant products, Article 2(13)(b) adds harvesting without inducing forest degradation after the cut-off. Article 2(7) identifies specific structural transitions involving primary forests, naturally regenerating forests, plantation forests, planted forests and other wooded land. This is not a general synonym for any forest damage.

A wood sourcing assessment therefore needs to establish both the absence of relevant agricultural conversion and the absence of the specified degradation induced by harvesting. Tree-cover recovery alone may not establish that the forest type remained acceptable under those definitions.

Keep evidence for the two conclusions distinguishable. A satellite time series may help establish cover history, while forest inventories, management records and regeneration evidence can help evaluate forest type and transition. Their usefulness depends on how accurately they describe the source area and period.

Evidence must connect to the goods

Start with the actual production plots or cattle establishments and link them to the relevant commodity in the products. Historical evidence about a nearby cooperative district does not establish the history of a particular supplier plot unless the sourcing connection and spatial coverage are reliable.

Use evidence suited to the question: dated imagery, land-use records, production records, forest management information and other credible sources can complement one another. Investigate conflicts, missing periods and unclear boundaries rather than treating a green map result as a legal determination.

The July 2026 Commission guidance explains that objective land characteristics and actual use matter. Administrative land categories can support the assessment, but a cadastral agricultural label does not override qualifying forest on the ground.

For example, a cocoa supplier might provide current farm polygons and a certificate, while the historical imagery shows a plantation was established in 2022. The reviewer should establish what land use preceded planting and whether it met the forest definition. If it was qualifying forest, the current agricultural tree cover and certificate do not remove the conversion issue. If the area was already agricultural, record the evidence supporting that earlier use rather than assuming every newly planted crop represents deforestation.

Use the definition in a documented decision

A useful conclusion identifies the goods, production locations, historical baseline, post-cut-off changes and reasoning under each applicable definition. Record unresolved uncertainty and the additional verification or mitigation needed before the operator reaches no or negligible risk. Do not reduce the process to a single unchecked supplier checkbox.

For operational review, the deforestation-free evidence checklist connects the legal test to the records supporting it. Reopen the conclusion when boundaries change, origins are substituted or credible new evidence identifies a previously missed conversion.

The result should be a supported product-specific assessment. A broad sustainability commitment may explain company policy, but the EUDR question is whether the relevant goods meet the defined conditions for their actual production land and, where applicable, harvested wood.