Reviewed by the editorial team of Symbol Consulting DMCC
EUDR in Slovakia is governed from 30. 12. 2026 by Regulation (EU) 2023/1115 as amended by Regulation (EU) 2025/2650 (primary source EUR-Lex, Regulation 2025/2650, Art. 38(2)) and by Act No. 81/2025 Z. z., which sets the authorities, supervision and fines (primary source Slov-lex, Act 81/2025 Z. z.). Regulation (EU) No 995/2010 on timber and Act No. 113/2018 Z. z. end, while older timber stays under the old regime until the end of 2029.
EUDR belongs to the ESG and compliance agenda of a manufacturer, yet its procedure is split between two texts that are read together: the regulation says who does what, the Act who checks it and what is at stake. Below they are assembled into one sequence, ending with three points where they diverge. The Act is amended by a government bill (print 1436), which as of 9. 11. 2026 is in committee proceedings, with the committees to discuss it on 17. 11. 2026; the proposed effect is 30. 12. 2026. The rates and the three points describe the wording from Slov-lex. The due-diligence system (Art. 8 to 11) and the classification of goods under CN codes are not covered.
EUDR in Slovakia: the regulation and Act No. 81/2025 Z. z. as two layers
Regulation (EU) 2023/1115 prohibits placing on the Union market or exporting cattle, cocoa, coffee, oil palm, rubber, soya and wood, and products made from them, unless they are deforestation-free, produced in accordance with the law of the country of production and covered by a due-diligence statement (Art. 3). Act No. 81/2025 Z. z. does not repeat these duties; it sets the authorities, supervision, sanctions and special rules for wood (§ 2 and 3).
The authorities are the Ministry of Agriculture, the Slovak Forestry and Wood Inspectorate (Slovenská lesnícko-drevárska inšpekcia) and, in military districts, the Ministry of Defence (§ 4(1)). Supervision is carried out by the inspectorate and the Ministry of Defence (§ 8(1)); the inspectorate decides at first instance on offences under § 13(1) and other administrative delicts under § 14(1) to (4) (§ 6(4)(e)); the Ministry of Agriculture decides at second instance (§ 5(d)) and at first instance on delicts of a market participant importing wood under § 14(5) (§ 5(c)). Imports of wood products from partner countries have a condition of their own: the licence must be submitted to the ministry before import (§ 3). For wood from Slovakia, compliance with the law of the country of production is deemed met if the wood comes from felling carried out under the special act (§ 2).
The base text has already moved twice. Regulation 2024/3234 set the start of application at 30. 12. 2025 and Regulation 2025/2650 moved it to 30. 12. 2026. In report COM(2026) 191 of 4. 5. 2026 the Commission stated that it „does not consider it appropriate to propose further amendments to the basic legal text“ (primary source EUR-Lex, COM(2026) 191). Annex I and the rules of the information system are being amended by separate Commission acts: Delegated Regulation 2026/2102 and Implementing Regulation 2026/1565.
Regulation (EU) No 995/2010 is repealed with effect from 30. 12. 2026, yet it continues to apply until 31. 12. 2029 to wood produced before 29. 6. 2023 and placed on the market from 30. 12. 2026 (Art. 37 as amended by 2025/2650). The Act follows this: until 30. 12. 2029 such wood remains under Act No. 113/2018 Z. z., which is repealed at the same time, and from 31. 12. 2029 the new Act applies (§ 15(3) and (4), § 16). Supervision and proceedings begun and not finished by 29. 12. 2026 are completed under Act No. 113/2018 Z. z. (§ 15(2)).
Roles in the supply chain and the dates of application
The regulation as amended by 2025/2650 distinguishes three roles: an operator who places products on the market or exports them, a downstream operator who places on the market products made using products covered by a statement, and a trader who only makes them available on the market (Art. 2 points 15, 15b and 17).
| Role | Definition (Art. 2) | Duties under the regulation as amended by 2025/2650 |
|---|---|---|
| Operator | Point 15: a person who in the course of commercial activity places the relevant products on the market or exports them, other than downstream operators | Due diligence before placing on the market or export (Art. 8(1)); a statement in the information system; records kept for five years (Art. 4(3)); reference numbers passed down the chain (Art. 4(7)) |
| Downstream operator | Point 15b: a person who places on the market or exports relevant products made using relevant products covered by a due-diligence statement or a simplified declaration | Collecting information on suppliers and customers and keeping it for at least five years (Art. 5(3) and (4)); unless an SME, registration in the information system before placing on the market (Art. 5(2)) |
| Trader | Point 17: a person in the supply chain other than an operator or a downstream operator who makes relevant products available on the market | The same duties as a downstream operator (Art. 5(2) to (4)) |
One company can hold several roles at once: report COM(2026) 191 states that the Commission guidance clarifies the identification of status in supply chains and „the possibility for a company to act as both importer and producer“.
The regulation applies from 30. 12. 2026 (Art. 38(2)). The deferred date of 30. 6. 2027 applies to natural persons, micro and small enterprises established as such by 31. 12. 2024, except for products covered by the annex to the timber regulation (Art. 38(3) of Regulation 2025/2650). For wood, 30. 12. 2026 therefore applies even to the smallest entities.
Product scope: Annex I after Delegated Regulation 2026/2102
The scope of products is set by Annex I of the regulation, which Commission Delegated Regulation (EU) 2026/2102 of 13. 7. 2026 amended with effect from 18. 9. 2026, the day after publication in the Official Journal on 17. 9. 2026 (primary source EUR-Lex, Regulation 2026/2102, Art. 2). Some items of rubber, hides and leather, and seats of aircraft and motor vehicles, dropped out; the new items apply from 30. 12. 2027.
| Change to Annex I | Items | From |
|---|---|---|
| Deleted | ex 4010 (conveyor or transmission belts of vulcanised rubber), ex 4016 (other articles of vulcanised rubber), ex 4101, ex 4104 and ex 4107 (hides and leather) | 18. 9. 2026 |
| Narrowed | Of ex 4012 only tyre treads remain (ex 4012 90 30); of 1201 only 1201 90 00 remains; ex 9401 is replaced by a list of subheadings without aircraft seats (9401 10 00) and motor vehicle seats (9401 20 00) | 18. 9. 2026 |
| Added | Frozen bovine tongues (ex 0206 21 00), coffee extracts (2101 11 00) and oil palm derivatives, for example ex 1516 20, ex 3401 11 00, ex 3824 99 and ex 3907 29 | 30. 12. 2027 |
The exceptions for wooden items were also specified. For wooden pallets and crates (ex 4415) they are used and second-hand products, „single-use packaging material and single-use packaging boxes used exclusively to support, protect or carry another product“, and clearly reusable packaging used in the same way.
Step-by-step procedure: from determining the role to keeping records
The procedure under the regulation as amended by 2025/2650 has seven steps: determining the role, classifying the product under Annex I, registration in the information system, due diligence with the statement, passing on reference numbers, making them available to customs, and five-year retention of records. The steps do not apply to everyone equally, because the duties depend on the role and on whether the entity is an SME.
- Determining the role: operator, downstream operator or trader (Art. 2 points 15, 15b and 17).
- Classifying the product by CN code under Annex I as amended by Regulation 2026/2102, including the exceptions for used products, waste and packaging.
- Registration in the information system for a downstream operator and a trader that are not SMEs; it must take place before placing the products on the market, making them available on the market or exporting them (Art. 5(2)).
- Due diligence by the operator before placing on the market or export (Art. 8(1)) and making the due-diligence statement available in the information system; the Act sanctions failure to make the statement available (§ 13(1)(c), § 14(1)(c)). Primary micro and small operators from low-risk countries file only a one-off simplified declaration (Art. 4a(2)).
- Passing the reference numbers of statements down the chain to downstream operators and traders (Art. 4(7)); they collect data on suppliers and customers (Art. 5(3)).
- On import, the reference number is made available to customs before release for free circulation by the person lodging the customs declaration (Art. 26(4)).
- Retention of records of statements and of information on suppliers and customers for five years (Art. 4(3), Art. 5(4)).
From 15. 10. 2026 statements in the information system are assigned to the competent authorities of the Member State in which the operator is established; for an operator established outside the Union, to the authorities of the Member State to which it is assigned by its unique identifier (primary source EUR-Lex, Regulation 2026/1565, Art. 1 point 2(c)). The Commission is to provide, no later than 30. 12. 2026, on a publicly available website, information on the availability of the system and on emergency measures for unplanned unavailability longer than 60 minutes; these include at least an emergency reference number of the statement (Art. 15a).
Supervision and fines under Act No. 81/2025 Z. z.
Supervision under Act No. 81/2025 Z. z. is carried out by an inspectorate employee on written authorisation and may enter premises or vehicles, require documents, take samples and process statement data in the information system (§ 8(1) and (2)). On a finding of breach, a protocol is drawn up and the supervised person has at least ten days for written objections (primary source Slov-lex, Act 81/2025 Z. z., § 10(1) and (2)).
Supervision carried out solely by a check in the information system runs without a protocol, and notices are delivered only through the system (§ 10(4) and (5)). For a high-risk product the supervisory authority may impose an interim measure suspending placing on the market or export; the period can be extended repeatedly by three working days (§ 11(1) and (2)). If the matter cannot wait, the authority decides on the spot, issues the written decision within 10 working days, and an appeal has no suspensive effect (§ 12). Obstructing supervision carries an administrative fine of up to 300 euros, and for a business or a legal person up to 1 000 euros (§ 10(7)).
| Provision | Breach | Rate |
|---|---|---|
| § 13(2) | Offence: placing on the market, making available or export contrary to Art. 3(a) of the regulation | 100 to 2 500 euros |
| § 13(3) | Other offences under paragraph 1(b) to (l) | Reprimand; on repetition 50 to 500 euros (statement not made available) or 50 to 250 euros (others) |
| § 14(6)(a) (for paragraph 1(a)) | Operator or trader that is not an SME: breach of Art. 3(a) | 500 to 50 000 euros or, for a legal person, up to 4 % of total annual turnover; where turnover cannot be determined, up to 50 000 euros |
| § 14(6)(c) (for paragraph 1(c)) | Operator or trader that is not an SME: statement not made available in the information system | 500 to 10 000 euros |
| § 14(6)(b) (for paragraph 1(b), (d) to (j)) | Operator or trader that is not an SME: Art. 3(b), due diligence, records, notification, reliance on a statement, information and evidence, risk assessment, reports | 300 to 4 000 euros |
| § 14(6)(d) (for paragraph 2(a)) | Operator that is an SME: breach of Art. 3(a) | 200 to 25 000 euros or, for a legal person, up to 4 % of turnover; where turnover cannot be determined, up to 25 000 euros |
| § 14(6)(i) (for paragraph 5(a)) | Market participant: fails to submit to the ministry, before importing wood products from a partner country, the licence for verification (§ 3) | 200 to 2 000 euros |
| § 14(6)(j) (for paragraph 5(b)) | Market participant: submits a licence that does not correspond to the original | 200 to 10 000 euros |
| § 14(6)(k) (for paragraph 5(c)) | Market participant: imports wood products from partner countries without a licence, contrary to the Act and the special regulation | 200 to 100 000 euros |
According to § 14(6)(k), the highest standalone fixed limit is 100 000 euros and applies to importing wood from a partner country without a licence, not to a breach of Art. 3(a), for which the basic limit is 50 000 euros. The table omits the lower rates of points (e) to (h) (50 to 3 000 euros).
For a repeated delict, or where the fine would be lower than the possible economic benefit, a fine of up to three times the upper limit under § 14(6)(a) or (d) may be imposed, which with the fixed limits means up to 150 000 euros and up to 75 000 euros (§ 14(8); own calculation). The percentage limit exceeds the fixed one at turnover above 1 250 000 euros, and for SMEs above 625 000 euros (own calculation from 50 000 / 0,04 and 25 000 / 0,04). Failure to comply with an imposed remedial measure is punished by a fine of 50 to 3 000 euros for an offence (§ 13(6)) and 100 to 50 000 euros for another administrative delict (§ 14(12)). A fine may be imposed within three years of discovery and at the latest within five years of the breach; the date of the protocol counts as discovery (§ 14(14)).
The sanction provisions are the subject of a government bill amending the Act (print 1436). The text of the bill rewrites § 14(3), deletes § 14(1)(g), § 14(2)(g) and § 14(6)(f), and amends § 13(3); it does not change the rates in § 13(2) and § 14(6)(a), (c) and (d). The table applies to the wording from 30. 12. 2026.
Three points where Act No. 81/2025 Z. z. does not match the new text of the regulation
Comparing Act No. 81/2025 Z. z. with Regulation (EU) 2023/1115 (primary source EUR-Lex, Regulation 2023/1115) as amended by 2025/2650 shows three points: the date of establishment of micro and small enterprises in § 15(5), the references to deleted paragraphs of Article 4 in footnotes 61 and 70, and the missing category of downstream operator. This describes the wording from 30. 12. 2026, not an interpretation.
| Point | Act No. 81/2025 Z. z. | Regulation as amended by 2025/2650 |
|---|---|---|
| § 15(5) | The Act applies from 30. 6. 2027 to micro and small enterprises that „arose by 31 December 2020“; footnote 78 refers to Art. 38(3) | Art. 38(3): established „by 31 December 2024“, application from 30. 6. 2027; in the wording of 2024/3234 the date was 31. 12. 2020 |
| § 13(1)(g), § 14(1)(g) and (2)(g) | Footnotes 61 and 70 refer to Art. 4(8) and (9) of the regulation (providing the reference number on request, relying on a statement already filed) | Art. 4(8), (9) and (10) are deleted („paragraphs 8, 9 and 10 are deleted“); reference numbers are governed by Art. 4(7) |
| § 14(1) to (3) | The offender is an operator or a trader (footnote 42: Art. 2 point 17); the expression „downstream“ does not occur in the Act | Art. 2 points 15, 15b and 17 separate three roles; Art. 5 imposes duties on downstream operators and traders |
The first difference is substantive: under the literal wording of § 15(5) the deferral to 30. 6. 2027 is tied to establishment by 31. 12. 2020, whereas the regulation ties it to 31. 12. 2024. The second concerns references: the sanction provisions cite paragraphs of Article 4 that no longer exist. The third is terminological: § 14 does not name a category that is separate in the regulation. The government bill (print 1436) touches all three: in § 15(5) it gives the date 31. 12. 2024, it deletes footnote 70 together with § 14(1)(g), it replaces footnote 61 with a reference to Annex III and Article 4a of the regulation, and it rewrites § 14(3) for the downstream operator. The amendment is not in Slov-lex as of 9. 11. 2026.
What to watch until 30. 12. 2026 and after
Several trackable points remain before application starts: the fate of the amendment, the Commission information on the information system, and the dates from which the circle of obliged entities and products widens.
- Amendment to Act No. 81/2025 Z. z. (print 1436): in committee proceedings as of 9. 11. 2026: the Committee for Agriculture and Environment and the Constitutional Law Committee are to discuss it on 17. 11. 2026 (also the deadline for discussion); proposed effect 30. 12. 2026; the next steps are the second and third readings, the President’s signature and promulgation in the Collection of Laws.
- 29. 12. 2026: the last day up to which supervision and proceedings already begun are completed under Act No. 113/2018 Z. z. (§ 15(2)).
- 30. 12. 2026: start of application of the regulation and repeal of the timber regulation; no later than that day the Commission provides information on the availability of the information system (Art. 15a).
- 30. 6. 2027: the deferred date for other micro and small entities (primary source European Commission, page on the regulation).
- 30. 12. 2027: application of the new items of Annex I.
- 30. 12. 2029: end of application of the timber regulation and of Act No. 113/2018 Z. z. to older wood.
Zdroje a dáta
Sources: Slov-lex, Act No. 81/2025 Z. z.; EUR-Lex, Regulations (EU) 2025/2650, 2023/1115, 2024/3234, 2026/2102 and 2026/1565 and report COM(2026) 191, Slovak version; European Commission page on the regulation. Status of the amendment: National Council of the Slovak Republic, government bill print 1436 (as of 9. 11. 2026). Own calculation: turnover limits of 1 250 000 and 625 000 euros, triples of 150 000 and 75 000 euros, comparison of three points.
This material was reviewed by the editorial team of Symbol Consulting DMCC, an advisory firm that provides company setup and licensing, tax and regulatory compliance, and market entry consulting across multiple countries.
The text is a general analysis of the regulations in force and is not legal, tax, immigration or financial advice.