EU Deforestation Regulation (EUDR)
What EUDR means for Portugal merch imports of cotton, leather, wood and paper from 2026.
The EU Deforestation Regulation (EUDR) entered force in 2023 with phased enforcement through 2025-2026. It prohibits placing on the EU market commodities and derived products if they are linked to deforestation after December 2020. Cotton, leather, wood and paper — all common merch materials — are covered. For Portugal buyers, every shipment from late 2025 onwards needs a due-diligence statement.
What due diligence requires: geolocation of every supplier farm or harvest area, satellite-verified evidence of no deforestation, risk assessment, mitigation measures, and a documented statement filed with EU authorities. For complex supply chains — a cotton T-shirt with cotton from three farms in two countries — the data assembly is non-trivial. We have built a EUDR-ready data pipeline for Portugal customers covering 100% of cotton and paper sourcing.
Practical impact in Portugal: paper greeting cards, cotton T-shirts, leather card-holders, wooden gift boxes all now require traceable origin documentation. Fines for non-compliance reach 4% of EU turnover. Our default for Portugal customers from January 2026 is fully EUDR-documented shipments at no incremental cost; if a project absolutely cannot meet EUDR (rare), we flag it and stop. The IVA 23% treatment is unchanged.
FAQ
Does EUDR cover synthetic textiles?
No — cotton yes, polyester no. But increasingly we recommend cotton-organic-with-EUDR for Portugal customers anyway for brand reasons.
How precise must geolocation be?
Per-plot for plots above 4 hectares; polygon-based for smaller plots. Cotton farms in our network are mapped to ±10 metres.
Audit risk?
EU authorities will audit a percentage of due-diligence statements. Falsified data carries significant penalties — keep evidence. We retain audit-grade files for Portugal for ten years.
Cost impact on merch unit price?
Minimal — typically 1-3% for cotton, more for leather where chain-of-custody is harder. We're absorbing most of this for Portugal customers in 2026.
What if a supplier can't provide EUDR data?
Switch supplier. By 2027 most viable EU-market suppliers will be EUDR-ready; we maintain a vetted list for Portugal buyers.