EUDR and Brazil

Brazil touches the EU's deforestation rule — the EU Deforestation Regulation (EUDR), which asks for proof that a product's land has carried forest continuously since the end of 2020 more broadly than any other origin: soy, coffee, cattle and wood are four of the seven commodities in scope, and Brazil ranks among the world's leading suppliers of each. The definitive application date of 30 December 2026 therefore lands on a wide sweep of Brazilian agribusiness at once.

Brazilian producers hold an underappreciated advantage here: the country's CAR rural registry and satellite monitoring infrastructure generate exactly the plot-level geolocation data the regulation demands. The group that assembles that data and files its own due diligence statements through its own EU entity converts a compliance burden into a commercial position.

What the regulation requires

Seven commodities fall within scope, together with a wide range of derived products: cattle, cocoa, coffee, palm oil, rubber, soy and wood. For each consignment the operator demonstrates three things: the goods are deforestation-free against a cut-off date of 31 December 2020, they were produced in accordance with the law of the country of production, and they are covered by a due diligence statement filed in the EU information system.

The December 2025 revision concentrated the filing obligation. The due diligence statement is submitted by the operator that first places the product on the Union market or exports it, while operators further down the chain collect, retain and pass on reference numbers. Geolocation of the production plots remains the demanding element, and customs controls at the border support enforcement.

The application date is 30 December 2026 for large and medium-sized companies, with 30 June 2027 for micro and small operators outside the timber sector. In its May 2026 simplification package the European Commission confirmed that the date stands and that a third postponement is off the table.

Keeping the compliance asset inside the group

Where a European buyer files the due diligence statement, the buyer becomes the operator the authorities examine, and the Brazilian exporter supplies the data that makes it possible. Where the Brazilian group holds its own Dutch entity, the roles reverse: the group registers as operator, files its statements built on its own CAR and monitoring data, and reaches European manufacturers as a European supplier with the paperwork complete.

For cooperatives and grouped supply chains, the May 2026 simplification allows all member farms to be mapped under a single consolidated due diligence statement, which lowers the per-farmer cost considerably.

The Article 23 licence defers import VAT to the periodic VAT return rather than the moment of clearance, releasing working capital on each consignment arriving in Amsterdam.

Practical points for Brazilian groups

Banking and notarial due diligence for Latin American ownership chains run on well-established rails in the Netherlands, home to one of Europe's largest Brazilian trade communities. Substance in the Netherlands supports the position that your entity genuinely places goods on the Union market, which serves you with the competent authority and the tax administration alike. The Netherlands and Brazil maintain a double tax treaty, and a renewed treaty is under negotiation in 2026.

Setting up in the Netherlands

A Dutch BV is incorporated by notarial deed and registered with the Chamber of Commerce. Incorporation runs remotely by power of attorney, with your parent company holding the shares. After registration the BV obtains its VAT number and EORI number, registers in the EUDR information system as an operator, and applies for the Article 23 licence that defers import VAT to the periodic VAT return.

Further reading: becoming the EU operator under the EUDR and fiscal representation and Article 23. Starting the entity itself: start from Brazil.

Frequently asked questions

Which Brazilian exports fall under the EUDR?

Soy, coffee, cattle and wood are the principal Brazilian commodities in scope, together with derived products such as soymeal, leather and furniture. Cocoa, palm oil and rubber complete the seven.

Who files the due diligence statement for Brazilian soy?

The party that first places the goods on the Union market. Where the Brazilian exporter sits outside the EU, that role falls to the first EU-established party in the chain — or to the exporter itself, the moment it holds its own EU entity and registers as operator.

What data does the statement require?

Geolocation of the production plots, evidence that the goods are deforestation-free against the cut-off date of 31 December 2020, and production in accordance with Brazilian law. Brazil's CAR registry and monitoring infrastructure supply much of this directly.

Does the Netherlands have a tax treaty with Brazil?

Yes, a long-standing treaty is in force and the two countries are negotiating a renewed treaty in 2026. Rotterdam is also the principal European port for Brazilian agricultural cargo.