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ESG
2026-08-278 min read0

EU Deforestation Regulation (EUDR) Takes Effect Dec 2026: Due Diligence Guide for Korean Exporters

The EU Deforestation Regulation takes effect for large and medium operators on 30 December 2026. This guide breaks down the due diligence statement requirements and a three-step supply chain readiness plan for Korean rubber, wood, paper, and packaging exporters.

KITIM Consulting Team

What Is the EUDR and When Does It Apply?

The EU Deforestation Regulation (EUDR) requires that certain commodities and derived products placed on, made available in, or exported from the EU market be proven free from deforestation. It replaces the earlier EU Timber Regulation (EUTR) with a far broader scope and a much higher evidentiary bar.

The compliance date is 30 December 2026 for large and medium-sized operators, as well as small operators already covered by the EUTR. Micro and small enterprises follow from 30 June 2027. Given that this timeline already reflects two postponements, betting on another delay is a poor strategy.

Seven commodities are covered: cattle, cocoa, coffee, palm oil, soy, rubber, and wood, along with their derived products. Three core requirements apply:

  • Deforestation-free: not produced on land deforested after 31 December 2020
  • Legality: produced in compliance with the laws of the country of production
  • Due Diligence Statement (DDS): submitted to the EU information system, generating a reference number
  • Which Korean Companies Are Actually Affected?

    This is not limited to raw agricultural exporters. The real exposure sits with processing and assembly manufacturers.

  • Tires and rubber components: HS 4011, 4016 and other natural-rubber-containing goods
  • Wooden furniture and flooring: HS 4407, 4409, 4412, 9403
  • Paper and packaging: HS 4801–4811, 4819 (corrugated boxes) — even the carton used to ship an unrelated product can fall in scope
  • Leather goods and food distribution: bovine leather, processed cocoa and coffee products
  • Korea is classified as a low-risk country under the Commission's country benchmarking. Two misconceptions follow from this.

    First, simplified due diligence is determined by the country where the commodity was produced, not the country of export. Most Korean rubber, wood, and paper manufacturers source raw materials from Indonesia, Malaysia, Vietnam, or Brazil — which means standard due diligence applies in practice.

    Second, even where simplification applies, the information collection and DDS submission obligations remain fully in force. Only the risk assessment and risk mitigation steps are waived.

    Even companies that do not export directly to the EU face indirect exposure transmitted through the supply chain, as EU buyers demand geolocation data and legality evidence to complete their own due diligence. Suppliers unable to produce these documents risk losing the account.

    What the Due Diligence Statement Requires

  • Geolocation of production plots: latitude and longitude to six decimal places. Plots larger than 4 hectares require a polygon boundary, not a single point.
  • Time of production: the date or date range of production on that plot
  • Legality evidence: land use rights, environmental protection, forest-related rules, third-party and indigenous rights, labour rights, and tax, trade and customs compliance
  • Risk assessment and mitigation records: satellite verification, third-party audits, supplier due diligence results
  • DDS submission and reference number: filed in the EU information system and passed downstream
  • The practical bottleneck is almost always geolocation data. Where raw materials pass through multiple intermediaries, tracing back to the originating plot typically takes six months or more.

    Three Practical Steps to Start Now

    Step 1 — Screen your scope by HS code

    Match your export items against the HS codes listed in EUDR Annex I. Even where the finished product is out of scope, packaging (HS 4819) frequently is not — so screen ancillary materials as well.

    Step 2 — Build a supplier data collection system

    Standardise a collection template covering geolocation, production timing, and legality evidence for each raw material supplier. Then write EUDR information obligations and non-compliance remedies into purchase contracts. Apply the new clauses to all new agreements immediately and amend existing ones at renewal.

    Step 3 — Document procedures and integrate

    Formalise your due diligence procedure as an internal policy with a designated owner. Because CBAM, the CSDDD, and the ESPR draw on substantially overlapping supply chain data, building a single integrated supply chain data platform rather than separate compliance silos will materially reduce duplicated cost.

    How KITIM Can Help

    The Korea Institute of Technology Innovation Management (KITIM) supports EUDR readiness through:

  • Scope diagnosis: HS code-based product screening and risk tiering
  • Supply chain data system design: supplier questionnaires, contract clause revisions, geolocation verification workflows
  • DDS preparation support: risk assessment documentation and filing assistance
  • Government programme linkage: guidance on the Korea Forest Service EUDR support desk, export voucher programmes, and trade association consulting
  • With roughly a year of effective lead time remaining before December 2026 — and geolocation collection alone often consuming half of it — now is the point to begin. If you are unsure whether the EUDR applies to your products, or an EU buyer has already requested documentation, contact KITIM. Our free preliminary assessment will identify your in-scope items and priority actions.

    EUDRDeforestation RegulationSupply Chain Due DiligenceEU ExportESG Regulation
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