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Supplier Risk and Compliance Author: Quibas Content Team

Two Months to EUDR: A Checklist for Turkish Exporters and Suppliers

Production plots marked on a map with a shipment route leading to a port

The EUDR applies from 30 December 2026. See what Türkiye's low-risk status does and does not change, which data your EU customer will ask for, and a two-month work plan in one checklist.

The EU Deforestation Regulation (EUDR) applies to large and medium-sized companies from 30 December 2026. In its May 2026 review report, the European Commission made clear that it does not plan another postponement. For Turkish exporters and for suppliers of companies selling into the EU, the remaining two months should go to the scope decision, data collection and data exchange with customers. This article complements our earlier piece on the buyer-side evidence chain from the supplier and exporter perspective.

Timeline: who applies when?

  • Large and medium-sized operators and traders: 30 December 2026.
  • Most micro and small operators: 30 June 2027.
  • Micro and small operators already covered by the EU Timber Regulation (wood products): 30 December 2026.
  • Small and micro operators file a simplified declaration instead of a due diligence statement, and SME downstream operators and traders mainly collect information only when there are substantiated concerns.

Are you in scope? Three questions

  • Is your product's customs (CN) code listed in Annex I? The relevant commodities are cattle, cocoa, coffee, oil palm, rubber, soya and wood, and derived products such as leather, furniture, paper, tyres and chocolate are listed too. The Commission also published a draft act on product scope in May 2026, so check the current list.
  • Does the product contain a relevant commodity, and in which country was that commodity produced? If a product made in Türkiye uses raw material from another country, the country of production of that raw material is what counts.
  • Who places the product on the EU market first? In most cases that is your importing EU customer. Your obligation then is not direct; it comes from supplying the data and evidence your customer needs. If you import through your own EU entity, you are the operator.

Türkiye's low-risk status: what it changes and what it does not

Commission Implementing Regulation (EU) 2025/1093 classifies Türkiye as a low-risk country, and the Commission's current country list shows the same status. Low risk means simplified due diligence for commodities produced in Türkiye: the operator still collects information, but if there is no risk of circumvention or mixing with products of other origins, it does not have to carry out the detailed risk assessment and mitigation steps. Authorities also check at least 1 percent of operators for low-risk countries, compared with 3 percent for standard risk and 9 percent for high risk.

Key takeaway: Low risk is not an exemption. The duty to collect information and geolocation data remains, and imported raw material carries the risk class of its own country of production.
  • For a chocolate maker using imported cocoa, a furniture maker using imported logs or veneer, or a tyre maker using imported rubber, the data your customer will ask for depends on the country the raw material came from.
  • If you keep Turkish-origin and imported inputs in the same stock, you need to show how you prevent mixing; otherwise the simplified route may not be available.

What will your EU customer ask for?

  • Product description, CN code, quantity and trade name; supplier and buyer details.
  • The country of production and the geolocation of the plots: a polygon tracing the boundary for plots above 4 hectares and a single latitude-longitude point for smaller plots, with at least six decimal places. For cattle, a point for each establishment where the animals were kept is required instead of polygons.
  • Information showing that the product was not produced on land deforested after 31 December 2020.
  • Evidence that the product was produced in line with the relevant laws of the country of production, such as land use rights, environmental, labour and tax rules.
  • If an earlier operator in the chain filed a statement, the reference number of that due diligence statement. The Commission's updated guidance also clarifies that several shipments can be covered by a single statement.

A work plan for the last two months

  • Weeks 1–2: Match the CN codes of your EU-bound products against Annex I and record the country of production of each raw material. Put the scope decision in writing with your legal and compliance team.
  • Weeks 3–4: Ask your own suppliers for plot geolocation and legality evidence. Use a standard form and track gaps and deadlines in one list.
  • Weeks 5–6: Separate Turkish-origin and imported inputs in stock and production, and document the separation. Add clauses on data delivery, updates and verification rights to your contracts.
  • Weeks 7–8: Agree the data format with your EU customers (for example GeoJSON for geolocation) and how statement references will be shared, and run an end-to-end test with one of your December shipments.
Key takeaway: The most common mistake is treating a certificate as enough on its own. A certificate is part of the evidence file; it does not replace plot geolocation and legality information.

Where Quibas helps

In Quibas you can collect the plot, legality and certificate information you need from suppliers through your own forms and document tasks in the supplier portal. Procurement, quality and compliance teams can define approval steps by product group or supplier type, and every revision request for missing evidence is recorded with its reason and timestamp. Quibas does not make the scope decision for you; it keeps your controls, evidence owners and human approvals in one traceable file.

Let's set up your EUDR data collection flow

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