EUDR for restaurants: what the deforestation rules mean
Coffee, cocoa, palm oil, soy and beef are all covered by the EU Deforestation Regulation — which is most of your supply chain. Here is the honest version of what a restaurant actually has to do, what it does not, and the questions to send your suppliers before December 2026.
TL;DR — Key Takeaways
The EU Deforestation Regulation (EUDR) is Regulation (EU) 2023/1115, the law that stops seven commodities — cattle, cocoa, coffee, oil palm, rubber, soya and wood — and the products listed in its Annex I from reaching the EU market unless they are deforestation-free, legally produced, and covered by a due diligence statement.
The European Commission expects the rules to cut at least 32 million tonnes of CO2 per year tied to EU consumption of those commodities (DG Environment).
Compare it to allergen law and the difference is the whole story. EU Regulation 1169/2011binds the person handing the plate to the guest. The EUDR binds whoever first places a covered product on the EU market — almost never the restaurant.
The correct move for a restaurant is supplier assurance, not paperwork. Ask every coffee, cocoa, palm-oil, soy, beef and wood-product supplier for their EUDR role and their due diligence statement reference numbers before 30 December 2026, and keep the answers.
Intermenu is where those answers become guest-facing— per-dish origin and sourcing notes on a live QR menu, translated into 15 languages, updated the day a supplier changes.
What is the EU Deforestation Regulation (EUDR)?
The EU Deforestation Regulation is Regulation (EU) 2023/1115, in force since 29 June 2023. It prohibits placing seven commodities and their listed derived products on the EU market, or exporting them, unless three conditions are met: the goods are deforestation-free, they were produced legally in the country of production, and they are covered by a due diligence statement.
"Deforestation-free" has a hard date attached: the commodity must come from land not deforested after31 December 2020, and wood must be harvested without inducing forest degradation after that same cut-off. A plantation cleared in 2019 is fine; the same plantation cleared in 2021 is not.
The EUDR replaced the old EU Timber Regulation (995/2010), which covered only wood, and it has been amended twice — by Regulation (EU) 2024/3234 and by Regulation (EU) 2025/2650. The second amendment did not just move dates; it redistributed who does what, which is why much of the EUDR guidance still online is now wrong.
Fix one thing in your head before reading on: scope is decided by customs codes, not by ingredients. A product whose HS code is not in Annex I is out of scope even if it is full of a covered commodity.
Which commodities does it cover, and why that hits restaurants
The EUDR covers seven relevant commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood. Between them they touch the espresso program, the dessert menu, the fryer oil, the steaks, the packaging and the pizza oven — which is why this lands closer to hospitality than most EU environmental law. What Annex I captures on the restaurant side:
Coffee— HS 0901: roasted or green, decaffeinated or not, plus husks and coffee substitutes containing coffee.
Cocoa— HS 1801 to 1806: beans, paste, butter, powder, and chocolate and other food preparations containing cocoa.
Oil palm— HS 1511 palm oil and 1513 21 / 1513 29 palm kernel oil, plus industrial fatty acids. Frying fats often sit here.
Soya— HS 1201 beans, 1208 10 flour and meal, 1507 soya-bean oil, 2304 oilcake used as animal feed.
Cattle— HS 0201 and 0202 beef, 0206 offal, 1602 50 prepared bovine meat, plus hides and leather at 4101, 4104 and 4107.
Wood— the whole 4401 to 4421 range, including 4402 charcoal and 4419 wooden tableware, plus pulp and paper of Chapters 47 and 48.
Rubber— HS 4001 to 4017, including 4015, which covers gloves of vulcanised rubber.
Here is the part almost nobody writes down: things you would swear are restaurant products fall outside Annex I because their HS code is not listed. The Commission's implementation FAQ names three that matter to food service — sausages and similar meat preparations of cattle (HS 1601), bread, pastry, cakes and biscuits whether or not containing cocoa (HS 1905 90), and coffee beverages (HS 2202 99).
A brewed cup of coffee is not a relevant product. A bag of beans is. That distinction explains most of what follows.
Does the EUDR apply to a restaurant, or only to importers?
For the overwhelming majority of restaurants, the EUDR applies indirectly. A plated dish is not an Annex I product, so serving food does not make you an operator, a downstream operator or a trader. You become a regulated actor only if you supply an Annex I product as that product— retail bags of coffee, chocolate bars, bottled oil, charcoal or firewood.
The three roles, because suppliers will start using the words at you:
Operator— first places a relevant product on the EU market or exports it: the importer or EU primary producer. Carries compliance responsibility and files the due diligence statement.
Downstream operator— created in December 2025. Places on the market products made from materials already covered by a statement. Processors and re-exporters sit here.
Trader— anyone else in the chain who makes a relevant product available on the market: distributors, wholesalers, retailers.
Apply it. You buy roasted beans from an EU roaster, brew them, serve espresso: the espresso is HS 2202 99, out of scope, so you are none of the three. You sell 250 g retail bags at the counter: you are making an Annex I product (HS 0901) available on the market, and you are a trader.
The Commission FAQ works through this exact shape — a contractor running an onsite restaurant buys chocolate (HS 1806) from an EU manufacturer and supplies it to guests. That contractor is a trader, but is explicitly not responsible for the EUDR compliance of the chocolate. That stays with the operator who imported it.
The honest summary for an independent restaurant, café or hotel F&B outlet: you are downstream, your obligation is commercial rather than regulatory, and your real exposure is suppliers passing costs and disruption down to you.
Large operators vs SMEs: the two different obligation sets
Size decides how heavy the duty is. Under Article 2(30) EUDR, "SME" follows the EU Accounting Directive 2013/34/EU: a medium-sized undertaking does not exceed at least two of a €25 million balance sheet total, €50 million net turnover, and 250 employees. Almost every independent hospitality business sits well inside that.
If you do land in scope as a trader or downstream operator:
Non-SME downstream operators and traders— must register in the EUDR Information System before making relevant products available, and where there are substantiated concerns must verify that due diligence was exercised before proceeding (Article 5(2) and 5(6)).
SME traders and downstream operators— no registration, no due diligence obligation, no verification duty. Collect and keep the Article 5(3) information, hand it over on request, and report immediately if you learn a product may be non-compliant.
Everyone in scope, any size— keeps for five years the name, address, email and web address of who supplied you and who you supplied, plus statement reference numbers where the supplier was an operator.
Invoices in a folder satisfy that duty. There is no requirement to store them in a specific system, and no requirement to check that the reference numbers you were given are valid.
The compliance dates — and how many times they moved
The EUDR has been postponed twice, by a year each time. The dates in force now are30 December 2026for large and medium operators, downstream operators and traders of all sizes, and micro and small enterprises handling former Timber Regulation products; and30 June 2027for operators who are natural persons or micro and small undertakings for the remaining products.
The sequence, because the number of stale posts on this topic is a genuine problem:
29 June 2023— entry into force. Original application: 30 December 2024 for large and medium operators, 30 June 2025 for micro and small.
December 2024— Regulation (EU) 2024/3234 pushes both back twelve months, to 30 December 2025 and 30 June 2026.
December 2025— Regulation (EU) 2025/2650 pushes them back twelve months again and simplifies the obligations. Parliament and Council dropped the proposed grace period in favour of a clean extension for everyone.
Now— Article 38 applies Articles 3 to 13, 16 to 24, 26, 31 and 32 from 30 December 2026, with the 30 June 2027 date reserved for operators who are natural persons or micro and small undertakings established as such by 31 December 2024.
There is no further postponement. Treat December 2026 as real — but treat it as your suppliers' date, because that is when their costs and paperwork start. Use the time to map which menu items depend on which commodity; on a structured menu in Intermenu that is a filter, not an afternoon with a spreadsheet.
Due diligence statements: who files them and what's in them
A due diligence statement (DDS) is an electronic declaration submitted through the EUDR Information System by the operator who first places a relevant product on the EU market. Restaurants do not file them. Downstream operators and traders do not file them either — they collect and keep the reference number of the operator's original statement.
Annex II sets out the contents: operator name, address and EORI number; the HS code, free-text description and quantity; the country of production and the geolocation of every plot of land where the commodity was produced — for cattle, every establishment where the animals were kept; the prescribed confirmation sentence; and a signature. The Information System launched on 4 December 2024 under Article 33.
Two clarifications from the December 2025 amendment are worth pinning up in the office. Only the first-placing operator files, and that operator keeps and transmits the reference number down the chain. And nobody downstream can file one even if asked— the Commission's FAQ is unambiguous that there is no legal obligation for a downstream operator or trader to submit a DDS, and the Information System offers no technical possibility to do so. A wholesaler demanding your statement has misunderstood the law.
What a restaurant should ask its suppliers now
Send one short questionnaire to every supplier of coffee, cocoa, palm oil, soy products, beef, charcoal, firewood, wooden tableware and paper goods. You are not auditing them. You are finding out whether their December 2026 becomes your February 2027 problem.
Which items you supply us are Annex I relevant products? Ask for HS codes, not adjectives.
What is your role— operator, downstream operator or trader?
Do you hold DDS reference numbers, and will you supply them on request?
Country and region of production for our coffee, cocoa and palm oil. This is also what you can put on the menu.
What is your continuity plan for 30 December 2026? Which lines are at risk, and what are the substitutes?
Do you expect price changes on in-scope lines, and when will you tell us?
Who is your named EUDR contact?
A template you can paste and send:
Subject: EUDR (Regulation (EU) 2023/1115) — supplier readiness
Ahead of the 30 December 2026 application date, please confirm for each line you supply us: the HS code and whether it is an Annex I relevant product; your role under the regulation; whether due diligence statement reference numbers are available on request; country and region of production; any anticipated price or availability impact; and your named EUDR contact. No response needed for lines outside Annex I.
File every reply. If you sell retail beans or bars, that folder is your Article 5 record. If you do not, it is still the best sourcing dossier you will ever have — and it drops straight into the origin fields on an Intermenu dish.
Penalties and enforcement
Article 25 requires Member States to set penalties that are effective, proportionate and dissuasive, and prescribes a floor: for a legal person, the maximum fine must be at least 4% of total annual Union-wide turnover in the financial year before the decision, increased where necessary to exceed the economic benefit gained.
The rest of Article 25(2):
Confiscation of the products concerned from the operator, downstream operator or trader.
Confiscation of the revenues gained from a transaction involving those products.
Exclusion for up to 12 months from public procurement and from access to public funding, grants and concessions.
Temporary prohibition on placing, making available or exporting relevant products, for serious or repeated infringements.
Loss of simplified due diligence under Article 13, for serious or repeated infringements.
Member States designate their own competent authorities, and under Article 25(3) the Commission publishes a list of final judgments against legal persons — company name, date, conduct and penalty. For a consumer-facing brand that list is arguably sharper than the fine.
Realistically, enforcement will go where the volume is: importers and large processors. A 40-cover restaurant is not the target. But "not the target" is not "not in scope" if you run a retail shelf.
Menu transparency: turning sourcing into a guest-facing asset
The EUDR does not require you to tell guests anything — there is no menu-labelling duty in Regulation (EU) 2023/1115. But you are about to collect country-and-region data on your coffee, cocoa and beef anyway, and leaving it in a spreadsheet wastes the only upside this regulation offers a restaurant.
Put it where guests read it:
ESPRESSO— Single-origin arabica, Huila, Colombia · roasted in-house
70% DARK CHOCOLATE TART— Cocoa from Ashanti, Ghana · supplier declaration on file
DRY-AGED RIBEYE— Grass-fed, County Meath, Ireland · 42 days
WOOD-FIRED MARGHERITA— Baked over certified European beech
Two cautions, because sourcing claims age badly. The moment you print an origin you have made a factual claim you must keep true — if the roaster switches lots in March, a printed menu is wrong until the next print run. And origin claims have to survive translation, where generic machine translation is very good at turning a region name into a mistranslated adjective.
That is the case for structured menu data rather than a design file. Intermenu stores origin notes as fields on the dish, so a supplier change is a two-minute edit that propagates to every language and every table at once, and its hospitality-trained translation keeps place names intact. The same per-item structure already carries your allergen and dietary labels and guest filters.
The wider playbook is in our guide to the sustainable restaurant menu, and the rhythm for changing supplier-driven items is in seasonal menu updates. The same argument runs through restaurant allergen compliance, special-diet menus, the EU AI Act rules on labelling AI images, and the wider restaurant technology stack.
Build a sourcing-transparent menu free with Intermenu →
Frequently asked questions
Does the EUDR apply to restaurants?
Usually only indirectly. A plated dish is not an Annex I relevant product, so serving food does not make you an operator, downstream operator or trader. You come into scope if you sell a listed product as such — retail coffee beans, chocolate bars, bottled oil, charcoal or firewood.
What is the current EUDR application date?
30 December 2026 for large and medium operators, downstream operators and traders of all sizes, and micro and small enterprises handling former EU Timber Regulation products. 30 June 2027 for operators who are natural persons or micro and small undertakings for the remaining products.
Which products does the EUDR cover?
Seven commodities — cattle, cocoa, coffee, oil palm, rubber, soya and wood — and only the derived products whose HS codes appear in Annex I: coffee 0901, cocoa and chocolate 1801 to 1806, palm oil 1511, soya beans 1201, beef 0201 and 0202, wood 4401 to 4421.
Does a restaurant have to file a due diligence statement?
No. The obligation sits exclusively with the operator who first places the product on the EU market. The Commission has confirmed there is no obligation for downstream operators or traders to submit one, and the Information System does not technically allow it.
Is coffee served in a cup covered by the EUDR?
No. Coffee beverages sit under HS 2202 99, which is not in Annex I. Roasted or green coffee under HS 0901 is covered. The bag is in scope, the cup is not.
Am I a trader if I sell retail bags of beans at the counter?
Yes — you are making a relevant product available on the EU market. As an SME trader your duties are limited to keeping supplier and customer records for five years and reporting non-compliance you become aware of. You are not responsible for the coffee's underlying compliance.
What is the EUDR cut-off date for deforestation?
31 December 2020. Commodities must come from land not deforested after that date, and wood must be harvested without inducing forest degradation after it. Land cleared before the cut-off does not breach the regulation.
Will the EUDR raise my food costs?
Probably, on some lines. Geolocation, risk assessment and statement filing are real costs for importers of coffee, cocoa, palm oil, soy and beef, and they move downstream. Ask suppliers for advance notice rather than finding out on an invoice.
Do I have to show sourcing on the menu?
No — the EUDR has no menu-labelling requirement. Origin information is a marketing choice, but a published origin claim has to stay accurate, which is why it belongs in a structured field on a digital menu like Intermenu rather than in a PDF.