The EU Deforestation Regulation (EU) 2023/1115 applies from 30 December 2026 to medium-sized and large companies. Anyone placing cattle, cocoa, coffee, palm oil, soy, wood or rubber on the EU market needs a due diligence statement from that day, along with the evidence behind it.
The Regulation says nothing about language. The translation work comes from two other directions: the evidence arriving from the country of production, and the questions you send there. This post sets out both.
This is an account of the legal position, not legal advice.
The Regulation requires a due diligence system in three stages: collect information (Article 9), assess risk (Article 10) and mitigate risk (Article 11). At the end sits the due diligence statement, submitted electronically through the EUDR information system on the TRACES platform.
The Article 9 information covers the description of the product, the CN code, the quantity, the country of production, the geolocation coordinates of the plots, details of suppliers and customers and verifiable evidence that production was deforestation-free and complied with the law of the country of production. That information has to be adequate, accurate and verifiable, and has to be kept for five years.
The second part is the harder one. The Regulation lists the areas of law whose compliance has to be shown: land use rights, environmental protection, forest-related rules, third-party rights, labour rights, human rights and the rules on tax, customs and trade, together with the principle of free, prior and informed consent. It does not say which documents prove any of this. That depends on the country of production, where the paperwork has different names, a different shape and the local language.
Regulation (EU) 2025/2650 postponed the start of application a second time and redistributed the obligations. Three points matter for the paperwork.
In practice the pile of documents is smaller than under the original version, but it concentrates on the elevated-risk cases. Those are exactly the supply chains furthest from Europe, and the ones least likely to document anything in German or English.
The EUDR names no language. It asks for verifiable information. Language becomes an issue along three routes.
Land titles, concession deeds, environmental permits, harvest records, employment contracts and official certificates arrive in Portuguese from Brazil, in Spanish from Colombia or Peru, in Indonesian, Vietnamese or French from West Africa. Someone in your own organisation has to understand what those documents say, because the risk assessment rests on them. A summary in a supplier portal rarely covers it: the assessment has to stand on the document, not on a description of it.
In Germany the Federal Office for Agriculture and Food (BLE) carries out the checks. German is the language of administrative proceedings, and under section 23 of the German Administrative Procedure Act the authority can require that foreign-language documents be submitted with a translation. Whether it does, and in what form, is decided case by case. Having the key pieces of evidence translated in advance shortens the check considerably.
The most underestimated point. Geolocation data, plot sizes and legal evidence have to come from farms that are often small and rarely work in English. A questionnaire in English sent to a coffee cooperative in Honduras or a rubber smallholding in Côte d’Ivoire produces queries, delays and, in the end, patchy data. Your response rate depends on whether the question is written in the producer’s working language.
| Document | Direction | What matters |
|---|---|---|
| Supplier questionnaire and data request | outgoing | the producer’s working language, plain wording, identical questions across all language versions |
| Code of conduct and supplier declaration | outgoing | decide which version is authoritative, keep legal terms consistent |
| Land titles, concessions, lease and use agreements | incoming | specialist translation, sometimes certified when submitted to an authority |
| Environmental and forestry permits | incoming | national forestry law has terms that do not map one to one |
| Certificates and audit reports | incoming | often already in English, which is usually enough |
| Internal procedure for the due diligence system | internal | every language spoken at the sites and buying offices involved |
Not every document needs the same treatment. Certificates and audit reports often arrive in English already. A land title that a risk assessment rests on is a different matter: there the exact wording decides whether the plot is lawfully farmed at all.
Around eleven weeks remain. That is no longer enough to document a supply chain from scratch, but it is enough for the language side if the work starts now.
Micro and small companies have until 30 June 2027 for their own deadline. The requests still reach them now, because their larger customers need the data before December.
tolingo works in more than 220 language pairs and is certified to ISO 17100, ISO 18587, ISO 9001 and ISO 27001. Three things count for EUDR documents.
When something has to move quickly, because a piece of evidence is needed for a check at short notice, there is express translation. Our language overview shows what is covered.
No. The Regulation asks for adequate, accurate and verifiable information but names no language. The language question is practical: it comes from the administrative procedure of the authority doing the checking, and from the fact that your own risk assessment rests on documents somebody has to be able to read.
No, and it would be poor economics. The sensible approach is to select by function: everything that goes out and is meant to come back answered, plus the incoming evidence that a risk assessment or a mitigation measure rests on. Certificates and audit reports are frequently in English already.
Not for the due diligence statement itself. Where a foreign document such as a land title or a concession deed is used as evidence before an authority or a court, a certified translation can be required. Check that case by case with the relevant body before having a whole pile certified.
Yes. Classification as a low-risk country under Implementing Regulation (EU) 2025/1093 allows simplified due diligence, but it does not remove the obligations. The Article 9 information, geolocation included, still has to be collected.
Since the revision, only the operator who first places the product on the market files its own due diligence statement. Downstream traders collect the reference numbers of the upstream statements and pass them on. Translation work there comes mainly from supplier communication and internal procedures.
Legal basis: Regulation (EU) 2023/1115 on EUR-Lex, in particular Articles 4 and 8 to 11 and Annex II, as amended by Regulation (EU) 2025/2650, together with Implementing Regulation (EU) 2025/1093 on country classification. Also the European Commission’s simplification package of 4 May 2026, with updated guidelines and FAQs, plus the guidance of the German Federal Office for Agriculture and Food on implementation in Germany. This post gives an overview and does not replace legal assessment of an individual case.
Which languages sit in your supply chain? Send us your countries of production and one sample document. We will tell you what can still be set up before the end of December. Head to our contact page, first response within ~10 minutes (within business hours).
Written by the tolingo specialist editorial team. Last updated: 8 October 2026.