Draft Polish Act Implementing the EUDR: New Obligations, New Inspections and Significant Business Risks
On 9 April 2026, draft bill UC101 was published to implement the EU Deforestation Regulation (EUDR) in Poland. For businesses trading in, among other products, timber, coffee, cocoa, soy, rubber, oil palm products or cattle, this means not only new documentation requirements but also an increased risk of inspections and substantial penalties.
Draft bill UC101 is intended to ensure the application in Poland of EU Regulation 2023/1115 (EUDR), which aims to reduce the impact of the EU market on deforestation and forest degradation. The EUDR covers cattle, cocoa, coffee, oil palm, rubber, soy and wood, as well as certain derived products. Member States are required to designate competent authorities, control procedures and enforcement mechanisms. According to the legislative work programme, draft UC101 falls within the responsibility of the Ministry of Climate and Environment, with adoption by the Council of Ministers planned for Q3 2026.
Available information indicates that the Polish Act will regulate, among other things, the submission of due diligence statements, rules for providing information to authorities, inspection procedures, corrective-action procedures and cooperation with customs authorities. The legislative work programme also identifies the authorities responsible for particular product groups, including the Environmental Protection Inspectorate, the Agricultural and Food Quality Inspection and the Veterinary Inspectorate.
From an operational perspective, the proposed obligations relating to the reference number of the due diligence statement are particularly important. Public commentary on the draft indicates that this number, or the identifier of a simplified declaration, will have to be included in commercial offers and transaction documents, including in online sales. At the same time, the absence of a valid number may result in a customs declaration for release for free circulation or export being refused.
The proposed penalties also merit particular attention. Commentary on the draft refers to administrative fines of up to 10% of annual turnover and the possibility of a temporary ban on activities involving the relevant products in cases of the most serious or repeated infringements. This shows that the EUDR is becoming not only a compliance challenge but also a real business and operational risk.
The key issue for businesses will now be determining whether their supply chains, commercial documentation and customs processes are ready for the new regime. In practice, it is worth assessing now whether the company has the appropriate data, procedures and internal responsibilities in place to demonstrate EUDR compliance once the Polish rules enter into force.
If you have any questions about draft bill UC101 or its impact on your company’s operations, please contact us.