EUDR and Morocco: Which Products Are Affected and What Importers Need to Do Before December 2026
- Agrilinkage
- 22 hours ago
- 13 min read
Published by AgriLinkage | Updated March 2026
There is a great deal of confusion circulating right now among European importers, Moroccan exporters, and sourcing professionals about what the EU Deforestation Regulation actually covers, and whether Moroccan products fall under its scope. Some have read alarming headlines and assumed that all Moroccan agricultural exports to Europe are now subject to new deforestation compliance requirements. Others have dismissed the regulation entirely, assuming it has nothing to do with Morocco. Both reactions are wrong, and both can cost you money.
This guide will give you the accurate picture, grounded in the text of Regulation (EU) 2023/1115 and the official implementing acts of the European Commission. We will tell you exactly which Moroccan products are affected, which are not, what the deadlines are, what Morocco's official risk classification means in practice, and what any operator, trader, or importer needs to do before December 30, 2026. Need help sourcing from Morocco, verifying a supplier, navigating a compliance requirement, or just figuring out where to start? AgriLinkage covers it all: supplier qualification, farm and facility audits, certification verification, contract negotiation, freight coordination, and EUDR compliance documentation. We have a team on the ground in Morocco, available seven days a week. WhatsApp +212 7 08 98 80 95 · contact@agrilinkage.com
What the EUDR Actually Is, and Why It Was Created
The EU Deforestation Regulation, formally known as Regulation (EU) 2023/1115, was adopted by the European Parliament on April 19, 2023, and published in the Official Journal of the European Union on June 9, 2023. It entered into force on June 29, 2023. It was developed as part of the European Green Deal, the EU's overarching strategy for achieving climate neutrality by 2050 and reversing biodiversity loss.
The regulation's purpose is narrow and specific: to ensure that products consumed within the European Union do not contribute to the destruction or degradation of forests anywhere in the world. The legislative logic behind it is straightforward. The FAO has documented the loss of approximately 420 million hectares of forest between 1990 and 2020, and the European Commission's own analysis estimated that EU consumption patterns were responsible for roughly 16 percent of deforestation linked to international trade worldwide. The regulation is the EU's legislative response to that responsibility.
The approach chosen was not to ban imports from specific countries. Instead, the regulation targets specific commodities that have been identified, through scientific research and satellite monitoring, as the primary drivers of agricultural expansion into forested land. Any company, anywhere in the world, that wishes to place these commodities on the EU market or export them from the EU must now prove that the products were not produced on land that was deforested after December 31, 2020.
The Seven Commodities: What EUDR Covers, and What It Does Not
This is the most important section of this guide for Moroccan exporters, and it is where the most confusion exists in the market.
The EUDR covers exactly seven raw commodities, along with the derived products manufactured from them. The seven commodities are: cattle, cocoa, coffee, oil palm, rubber, soya, and wood. The derived products covered include, among others: beef, leather, chocolate, cocoa butter, coffee preparations, palm oil, palm kernels, glycerol derived from palm, natural rubber, rubber tires, soya meal and oil, wood in all processed forms including furniture, paper, cardboard, and charcoal. The full list is set out in Annex I of the regulation, organized by customs code under the Combined Nomenclature (CN). If a product's CN code does not appear in Annex I, it is outside the scope of the EUDR.
The following products are entirely outside the scope of the EUDR:
Tomatoes, citrus fruits, berries, avocados, peppers, courgettes, potatoes, onions, garlic, herbs, fresh vegetables of any kind, fish and seafood products, olive oil, argan oil, preserved vegetables, fruit juices, spices, dairy products, eggs, cereals, sugar, textiles made from cotton or synthetic fibers, and any product whose CN code does not appear in Annex I of the regulation.
This is a critical distinction for Morocco. The country's dominant agricultural exports to the European Union, which include tomatoes, clementines and other citrus, fresh peppers, courgettes, strawberries, blueberries, avocados, fresh herbs, sardines and anchovies, olive oil, and argan oil, are not covered by the EUDR. The regulation does not apply to them. No due diligence statement, no geolocation data, no deforestation risk assessment is required for these products when they are exported to the EU.
The confusion in the market appears to come from several sources. First, some news coverage of the EUDR has been written loosely, referring to "agricultural exports" broadly without specifying which commodities are covered. Second, olive oil in particular has frequently been mentioned alongside EUDR discussions, which is entirely incorrect. Olive oil does not derive from any of the seven commodities in scope and is not listed in Annex I. There is no EUDR obligation attached to Moroccan olive oil exports.
Which Moroccan Products Are Affected by EUDR
The honest answer requires looking at each of the seven covered commodity sectors and asking whether Morocco produces and exports products derived from them to the EU.
Cattle and leather. Morocco has a significant cattle farming sector and a centuries-old leather tanning industry centered in Fez, Marrakech, and Casablanca. Leather goods and accessories produced in Morocco, including bags, belts, shoes, and decorative items made from cowhide, fall within the scope of the EUDR if the raw hides or leather inputs are derived from cattle. According to data published by the Centre for the Promotion of Imports from Developing Countries (CBI), Morocco is among the growing exporters of leather accessories and leather bags to the European market. Any Moroccan exporter sending leather goods derived from cattle hides to EU buyers needs to understand their EUDR obligations.
It is important to note a technical nuance here: the EUDR covers specific CN codes in Annex I. Finished leather products such as handbags made from full leather may not fall under the regulation in exactly the same way as raw hides or wet-blue leather. The obligation is determined by the specific CN code of the product, and operators must verify their position against Annex I. However, anyone in the supply chain who places raw cattle hides, wet-blue leather, or crust leather on the EU market does carry clear due diligence obligations under the EUDR.
Note also that a pending European Commission delegated act, which was signaled in February 2026 and expected to open for public feedback in spring 2026, may adjust certain Annex I product listings. Whether leather products remain in scope or are partially removed is actively under discussion. Operators in the leather sector should monitor this development closely, and until the delegated act is formally published and enters into force, the current Annex I is the applicable legal text.
Wood and wood products. Morocco exports wooden furniture, carved woodwork, and decorative wooden products to Europe, particularly from artisan workshops in Essaouira, Fez, and other craft-producing regions. If these products are made from wood and their CN codes appear in Annex I of the EUDR, they fall within scope. Wooden furniture, wood paneling, wood flooring, paper, cardboard, and similar products are all specifically listed. Any Moroccan exporter of wooden furniture or wood-based products to the EU needs to verify the CN codes of their products against Annex I and assess their EUDR compliance position. Note that printed products, including books and publications, were removed from the scope of the EUDR by the December 2025 amending regulation.
Rubber. Morocco produces and exports some rubber products, and any natural rubber or vulcanized rubber article listed in Annex I that is placed on the EU market is subject to EUDR requirements.
Cocoa, coffee, soya, and palm oil. Morocco is not a significant primary producer of cocoa, coffee, soya, or palm oil. However, if Moroccan food manufacturers produce chocolate products, coffee preparations, soy-based ingredients, or palm oil derivatives and export them to the EU, those products may be covered by the EUDR depending on their CN code. This applies to any processed food company in Morocco whose products contain these commodities as inputs.
The Compliance Deadlines in Full
The EUDR has been through two rounds of postponement. The first was introduced by Regulation (EU) 2024/3234, adopted in December 2024, which extended the original 2024 deadline by twelve months. The second postponement was introduced by Regulation (EU) 2025/2650, published in the Official Journal on December 23, 2025, which extended it by a further twelve months. The current timeline is as follows.
For large and medium operators, meaning companies that do not qualify as micro or small enterprises under EU definitions, the EUDR becomes enforceable on December 30, 2026. From that date, any covered commodity or derived product placed on the EU market or exported from it must be accompanied by a Due Diligence Statement uploaded to the European Commission's EUDR information system.
For micro and small operators, meaning natural persons and enterprises with fewer than 50 employees and an annual turnover related to the covered products of less than ten million euros, the application date is June 30, 2027, with one important exception: micro and small operators who were already covered by the previous EU Timber Regulation (EUTR) must comply from December 30, 2026, on the same timeline as large and medium operators.
These dates are not suggestions. From December 30, 2026, EU customs authorities will begin enforcing compliance, and products without a valid Due Diligence Statement can be blocked at the border, confiscated, or refused market access. Fines for non-compliance can reach at least four percent of a company's total annual EU turnover, with the possibility of additional penalties for serious or repeated infringements, including temporary exclusion from public procurement and bans from placing products on the market.
A European Commission simplification review is required to be completed and reported by April 30, 2026, assessing the regulation's administrative impact, particularly on smaller operators, with the option of a further legislative proposal. The country risk classification will also be reviewed in 2026 using updated FAO forest data.
Morocco's Country Risk Classification Under EUDR
One of the most consequential developments of 2025 was the publication, on May 22, 2025, of the European Commission's first official country risk classification under the EUDR's benchmarking system. This system assigns each country one of three risk levels: low, standard, or high.
This classification has direct and practical implications for anyone sourcing covered commodities from Morocco. Under the simplified due diligence procedure available to operators sourcing from low-risk countries, the full risk assessment and risk mitigation steps required under standard and high-risk procedures are not mandatory. Operators must still collect all information required by Article 9 of the regulation, including the geolocation coordinates of the production plots, details of the commodity, the quantity, the country of origin, and the supplier's information. They must still submit a Due Diligence Statement to the EUDR information system before placing the product on the EU market. But they are not required to conduct a formal risk assessment or implement risk mitigation measures, provided there is no indication that circumvention is occurring or that materials from higher-risk origins have been mixed into the supply chain.
A total of 140 countries received this low-risk classification, including all 27 EU member states, the United Kingdom, the United States, Canada, China, Japan, and Australia. For comparison, the only four countries classified as high risk are Belarus, Myanmar, North Korea, and Russia, all of which are subject to UN or EU sanctions that make supply chain due diligence impossible to conduct. Brazil, Indonesia, and Malaysia, which are the world's primary sources of cocoa, palm oil, rubber, coffee, and soya, are classified as standard risk and subject to full due diligence requirements.
Morocco's low-risk classification is an important competitive advantage for Moroccan exporters of covered commodities. It means that European buyers sourcing leather, wood products, or rubber goods from Morocco face a significantly lighter compliance burden than they would when sourcing the same products from Brazil, Indonesia, or other standard-risk origins.
It is critical to understand, however, that low-risk does not mean no-effort. Even for products from low-risk countries, operators must still collect and document the required information, submit the Due Diligence Statement, and be prepared to demonstrate that their supply chain does not involve mixing with materials from standard or high-risk origins. The compliance challenge has shifted from form-filling to evidence-building, and companies that interpret the low-risk classification as an exemption from the regulation are making a serious strategic error.
What the EUDR Requires in Practice
For any Moroccan exporter or their EU-based importer handling covered commodities, the EUDR requires the following process.
First, the operator, which under the regulation means the company that first places the product on the EU market or exports it, must collect specific information about the product. This includes the geolocation coordinates of the plots of land where the relevant commodity was produced or raised, the date or date range of production, the quantity and description of the product with its CN code, the name and address of the supplier and buyer, and information confirming the product was produced in compliance with relevant laws of the country of origin.
Second, for products from Morocco (a low-risk country), the operator must confirm that no circumvention risk exists and that the supply chain does not include mixing with inputs from standard or high-risk origins. The full risk assessment steps of Articles 10 and 11 are not required.
Third, the operator must submit a Due Diligence Statement through the EUDR information system before the product is placed on the EU market. Upon submission, the system generates a reference number that must be included in the customs declaration.
Fourth, the operator must keep records of all due diligence documentation for five years and be prepared to provide them to the competent national authority of the EU member state where the product enters the market.
Following the December 2025 amendments, downstream operators and traders (companies that buy and resell covered products within the EU after a Due Diligence Statement has already been submitted by an upstream operator) have significantly lighter obligations. Non-SME downstream operators must register in the information system and collect declaration reference numbers, but they no longer need to submit their own full due diligence statement. Micro and small primary operators may submit a single one-time simplified declaration rather than a declaration per shipment.
The Position of Moroccan Institutions
Morocco's Ministry of Agriculture, Fisheries, Rural Development, and Water and Forests, along with its technical agencies ONSSA (Office National de Sécurité Sanitaire des Produits Alimentaires) and Morocco Foodex, has been actively engaged in preparing the export sector for increasing European regulatory demands. Since 2023, Morocco Foodex has expanded its technical assistance programs to exporters on international certification requirements, and the ministry has accelerated the rollout of parcel-level geolocation systems and traceability tools across key export sectors. These systems, which assign precise GPS coordinates to agricultural parcels and link them to digital export documentation, are directly relevant to EUDR compliance for any covered commodity.
The broader context here matters. Morocco exported 85.8 billion dirhams worth of agricultural products in 2024, a growth of 3.1 percent over the previous year, with the European Union accounting for approximately 62 percent of total Moroccan trade flows. The EU is not merely Morocco's largest trading partner; it is the foundational market on which Morocco's entire agricultural export strategy is built. Maintaining smooth access to that market as European regulatory requirements evolve is not optional.
A Summary Table for Buyers and Exporters
The following is a plain-language reference of the most common Moroccan export products and their EUDR status.
Product | EUDR Status | Notes |
Tomatoes | Not covered | CN codes not in Annex I |
Citrus fruits (oranges, clementines, etc.) | Not covered | CN codes not in Annex I |
Strawberries and berries | Not covered | CN codes not in Annex I |
Avocados | Not covered | CN codes not in Annex I |
Fresh peppers, courgettes, herbs | Not covered | CN codes not in Annex I |
Olive oil | Not covered | Not derived from a covered commodity |
Argan oil | Not covered | Not derived from a covered commodity |
Sardines, anchovies, seafood | Not covered | CN codes not in Annex I |
Leather goods (from cattle hides) | Potentially covered | Verify specific CN code against Annex I; pending delegated act may affect scope |
Wooden furniture and carved wood | Potentially covered | Verify specific CN code against Annex I |
Natural rubber products | Potentially covered | Verify specific CN code against Annex I |
Chocolate or cocoa-based products | Potentially covered | If CN code is in Annex I |
Coffee preparations with covered inputs | Potentially covered | If CN code is in Annex I |
Morocco's country risk level | Low risk | As of May 2025 EC benchmarking implementing act |
What Moroccan Exporters and Their EU Partners Should Do Now
The enforcement date of December 30, 2026 is nine months away as of this writing. That is not a comfortable margin, particularly for companies that need to build traceability systems from scratch, negotiate new information-sharing protocols with their suppliers, or register on the EUDR information system for the first time.
Any Moroccan exporter selling leather goods, wooden furniture, or rubber products to the EU should immediately verify whether the CN codes of their specific products appear in Annex I of Regulation (EU) 2023/1115. If they do, the exporter should begin collecting geolocation data for their supply chain, identify which party in the EU will serve as the operator responsible for submitting the Due Diligence Statement, and establish a documentation system that can be maintained and audited for at least five years.
Any EU importer sourcing covered commodities from Morocco should register with the EUDR information system if they have not already done so, establish clear contractual arrangements with their Moroccan suppliers specifying who is responsible for collecting what information, and take advantage of Morocco's low-risk classification by building a supplier file that documents the supply chain clearly and confirms the absence of material mixing with standard or high-risk origins.
Any EU importer sourcing non-covered Moroccan products, including tomatoes, citrus, berries, olive oil, argan oil, or seafood, does not have EUDR obligations for those specific products. Their compliance obligations with respect to Moroccan agricultural exports are governed by other EU frameworks, including the Association Agreement between the EU and Morocco, phytosanitary requirements under EU plant health regulations, and maximum residue level rules for pesticides.
Sources and References
This article is based on primary sources only. All regulatory information has been verified against official texts.
Regulation (EU) 2023/1115 of the European Parliament and of the Council of 31 May 2023, as consolidated including all amendments through December 2025.
Regulation (EU) 2024/3234 of December 19, 2024, first postponement of the EUDR application dates.
Regulation (EU) 2025/2650 of December 2025, second postponement and amendment of the EUDR.
European Commission, EUDR Country Classification List, published May 22, 2025 via the European Commission Green Forum.
Morocco Ministry of Agriculture: agriculture.gov.ma
Morocco Foodex: foodex.gov.ma
ONSSA (Office National de Sécurité Sanitaire des Produits Alimentaires): onssa.gov.ma
Centre for the Promotion of Imports from Developing Countries (CBI), European Market Potential for Leather Accessories and Leather Bags: cbi.eu
Have a question about your supply chain, a supplier you need looked at, or a compliance deadline coming up? Don't hesitate to reach out, our team is on the ground in Morocco and ready to help with whatever your operation needs, seven days a week.
WhatsApp +212 7 08 98 80 95 · contact@agrilinkage.com
This article is published for informational purposes and does not constitute legal advice. Operators with specific compliance questions should consult the official guidance documents published by the European Commission or seek qualified legal counsel.
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