Is Thailand Ready for EU Regulations?
The European Union (EU) country classification list for products covered by the European Union Deforestation Regulation (EUDR) designates Thailand as a “low risk” country. Overall, Thailand is institutionally advanced and benefits from this low‑risk classification, but full EUDR readiness remains uneven, with farm‑level and smallholder compliance the main bottlenecks.
This article reviews Thailand's preparedness for EUDR, Due Diligence, and related regulatory benchmarks required to access EU markets.
Background
Thailand has taken significant steps toward preparedness for the EUDR and was designated as “low‑risk” under the EU’s EUDR country classification in June 2025. The classification means that operators and traders importing EUDR-regulated products from Thailand face simplified due diligence obligations, with only 1% of consignments subject to compliance checks.
“This means that products exported from Thailand to the EU will be subject to less stringent requirements for documentation, traceability, and evidence of compliance compared to those from Standard-Risk countries like Malaysia, Indonesia, and Cambodia, or High-Risk countries such as Myanmar.”
“Low risk” designation does not exempt these products from due diligence obligations, nor does it protect individual smallholders if they cannot provide plot‑level coordinates and legality documentation.
Structural gaps remain, particularly in smallholder inclusion, geolocation, and interoperability among traceability systems.
The Importance of Complying with EU Regulations
EUDR compliance applies to rubber, palm oil, timber, coffee, cacao, soy and beef products. The legislation came into force for large companies on December 30, 2026, and will apply to small and medium-sized businesses from June 30, 2027.
Thailand’s ability to comply is critical, given that in 2024 the country exported over USD 694 million in EUDR-covered commodities to the European Union. Timber, rubber, and palm oil account for the bulk of these exports. Trade in coffee and cacao remains comparatively small but continues to increase.
To maintain access to the EU market and increase exports, Thailand must ensure traceable supply chains and demonstrate environmental responsibility. Complying with EUDR requires extensive data, including production plot coordinates, land rights documentation, and the preparation of Due Diligence Statements (DDS).
A standardized central system linking these data can reduce workload and costs and limit the risk of lost trade opportunities. This is critical for smallholder farmers.
Regulatory and policy preparedness
At the policy and system‑design level, Thailand is comparatively advanced and politically committed to aligning with EU regulations. Thai government agencies, including forestry, agriculture, and trade, have been formally discussing EUDR impacts since at least 2022, drawing on FLEGT and timber‑sector experience (supply‑chain control, multi‑stakeholder processes) as a model for broader agricultural and timber preparedness.
Existing legal controls and supply‑chain monitoring in the timber sector offer useful lessons for rubber, palm oil, cacao, and other commodities covered under the EUDR, particularly regarding documentation, chain‑of‑custody, and risk‑information requirements for EU buyers.
The EUDR Thailand Traceability Platform, a national traceability platform specifically designed to support EUDR compliance, was officially launched in January 2026. The platform aims to provide a unified system for operators to demonstrate deforestation‑free production through:
geolocation of plot-level coordinates using satellite imagery
land‑use verification
legal compliance information
agricultural mapping standards
The platform is backed by at least nine funded research projects on traceability, land‑rights verification, and a review of Thai timber law.
Although Thailand has launched concrete digital and project‑based systems that can generate EUDR‑relevant data, especially for rubber and timber, these systems are still in a scaling-and-integration phase. Meanwhile, organizations such as ECOSHIFT, Koltiva, and RSPO provide various levels of support to help producers comply with the EUDR and export their goods.
Sector-specific review
Timber
Thailand’s Timber Legality Assurance System (TH‑TLAS) has been under development since 2013, initially as part of FLEGT Voluntary Partnership Agreement (VPA) negotiations with the EU, and now continues independently. Its core objective is to ensure that only legally produced timber enters the supply chain and that it can be traced from harvest to export, using a risk‑based system of checks.
A legal definition and a supply‑chain‑control system were developed by reviewing relevant forestry laws, mapping the timber supply chain, and identifying legal and governance gaps that require reform. This produced clearer rules for harvesting permits, transport documentation, processing, and export licensing, along with mechanisms for independent monitoring and verification.
The TH‑TLAS relies on supply‑chain control measures that track timber flows from harvest to export, including log marking, transport waybills, mill input–output reconciliation, and documentation at export terminals. These measures are designed to prevent illegally harvested domestic timber or unverified imported timber from entering the licensed supply chain. They are directly relevant to EUDR’s traceability and risk assessment requirements.
An important component for EUDR compliance is the self‑declaration (SD) procedure for timber from private land, developed by the Royal Forest Department under TH‑TLAS. Self-declaration standardizes how smallholder and community timber producers collect geolocation data and legal documentation, such as evidence of land rights and harvest permits, to support the documentation EU importers must include in their Due Diligence Statements. Recent EU‑commissioned assessments confirm that the SD mechanism can help provide EUDR‑compliant information on legality and origin, especially under Articles 9 and 10.
Despite this relatively advanced framework, challenges remain. TH‑TLAS is not yet fully implemented nationwide, FLEGT licensing is not operational, and some smallholder producers still struggle with the administrative burden of self‑declaration and the cost of complying with documentation requirements. In addition, interoperability between TH‑TLAS datasets, the new EUDR Thailand Traceability Platform, and private certification schemes remains a work in progress, making it difficult for EU operators to obtain seamless, digital access to all required information.
Thailand’s timber sector demonstrates that legally robust, supply‑chain‑wide systems can be built and leveraged to generate EUDR‑compliant data. The remaining task is to complete implementation, expand smallholder support, and integrate TH‑TLAS more tightly with national and private digital platforms so that timber exporters can deliver standardized, verifiable information to EU buyers at scale.
Source: Forest Trends
Rubber
The rubber sector is responding to the EUDR requirements by helping farmers provide relevant information, including formal land titles for smallholders, verifiable geolocation data, and consistent plot‑level traceability.
Although mixing rubber at multiple collection points also makes it difficult to trace products back to specific plots, an estimated 90% of rubber farmers are registered with the Rubber Authority of Thailand (RAOT). This lays the groundwork for obtaining legal documents certifying their products, including geolocation coordinates and plot areas for the majority of registered smallholders.
To facilitate EUDR compliance, the "TRT – Thailand Rubber Trade" system is being developed to connect to the RAOT database, streamlining the process for rubber traders by integrating essential DDS documentation.
While government initiatives evolve, private and mixed public‑private initiatives are expanding. For example, GT Rubber, in collaboration with Koltiva, has mapped over 15,000 rubber plots and verified 4,500 farmers in a deforestation‑free traceability project, with plans to onboard at least 10,000 smallholder producers by 2027.
“Thailand is the European Union's (EU) second most important supplier of rubber goods. Imports of rubber and rubber products account for 90% by value of exports from Thailand to the EU of EUDR goods. The EU buys 11.5% of Thai rubber and related goods.”
Palm oil
The EUDR will impact the over 407,000 Thai households that depend on palm oil. These smallholders account for over 70% of Thailand's palm oil production, helping make it the world's 3rd-largest producer.
As most palm oil plantations are on land previously used for other agricultural purposes rather than recently deforested land, farmers often have legal rights to this land. However, they generally lack sufficient knowledge of sustainable farming practices and other requirements to comply with the EUDR.
Only 2% of growers have met the sustainability standards set by the Roundtable on Sustainable Palm Oil (RSPO). The RSPO certifies environmental and social standards, including fair labour practices, community impact mitigation, and regulatory compliance. The organization is gaining traction, and the industry is shifting toward more efficient production models and reducing deforestation.
As a result, this sector will require strong support to prepare for the EUDR.
Cacao
Cacao is overwhelmingly cultivated by smallholders in the southern provinces of Pattalung, Nakhon Si Thammarat, and Chumphon – home of the Chumphon No. 1 variety – as well as in Chiang Mai and Nan in the north. As growing and fermenting techniques mature, an increasing number of farms are gaining recognition for premium Thai cocoa beans and unique flavour profiles.
Initiatives such as Chulalongkorn University’s Institute for the Study of Thai Cacao (ISTC) are leading research in Nan and other northern provinces. In southern provinces, ECOSHIFT is assembling a collective of smallholders and supporting EUDR compliance, including ground-level plot geolocation, farm assessments, heavy-metal testing, and supply chain tracking and verification.
As climate change and disease disrupt supply in West Africa, increased government support of this nascent sector is warranted, starting with relevant government bodies identifying and supporting smallholder cacao farmers.
Coffee
According to data from the Department of Business Development, Thailand cultivates both Arabica and Robusta varieties across more than 220,000 rai of farmland, yielding around 40,000–50,000 tonnes annually. Less than 5,000 tonnes are classified as specialty coffee.
Although there are few public statistics on the precise percentage of smallholder coffee farmers, policy and project documents describe production as based on small farms. Similarly, development programs specifically target “smallholder coffee farming systems” and farmer groups, with no evidence of a significant estate sector dominating production.
According to Coffee Culture, “Premium-grade Thai Arabica, grown in regions such as Chiang Mai and Chiang Rai, has garnered global attention for its quality and unique flavour profiles.” Expanding exports to the EU will depend on compliance with the EUDR.
Smallholders and Supply‑chain Structure
Smallholders dominate Thailand’s forest‑risk production. Approximately 70 percent of the palm‑oil area and 88 percent of rubber plantations are managed by smallholders, making their inclusion decisive for EUDR compliance.
Field experience in EUDR‑oriented projects shows smallholders face limited awareness of traceability and compliance requirements, constrained access to technology and connectivity, and logistical barriers to real‑time data collection, despite targeted training and onboarding efforts by organizations such as Koltiva, ECOSHIFT, and Wild Asia.
System‑level readiness is ahead of farm‑level readiness. Without large‑scale support for smallholders, the national “low‑risk” status may not translate automatically into robust, plot‑level due diligence across all supply chains.
Assessing the strengths and weaknesses of Thailand’s EUDR preparedness
Strengths
Political recognition of EUDR and active government coordination with EU counterparts indicate that Thailand recognizes the importance of traceability and regulatory compliance. Its official low‑risk classification under the EUDR eases some compliance requirements, and the launch of a national EUDR traceability platform is a positive development. Existing experience in the timber sector can inform rubber and other commodities.
Weaknesses
Although Thailand is developing and improving compliance mechanisms in alignment with EUDR and other regulatory policies, gaps remain. System‑level readiness is ahead of farm‑level readiness, and without large‑scale support for smallholders, the national “low‑risk” status may not automatically translate into robust, plot‑level due diligence across all supply chains.
Overcoming the following readiness challenges can help smallholders comply and access EU markets:
Traceability: Coverage of smallholders in digital traceability systems is incomplete, and many producers are not yet fully mapped or integrated.
Land-title documentation: Ongoing challenges with land‑title documentation, plot‑level geolocation, and mixing in multi‑tier supply chains, especially for rubber and palm oil.
Awareness: Capacity and awareness constraints among smallholders and SMEs, who face resource and knowledge gaps despite being central to EUDR‑relevant production.
Opportunities for Thai Agricultural Products
Thailand has clear opportunities to turn EUDR compliance into a competitive advantage for its agricultural and forestry sectors, rather than treating it solely as a constraint. These opportunities can be realized more fully if they are explicitly linked to public policy and state-led action.
Thailand can increase exports of specialty and value‑added products to the EU by pairing strong product identities with demonstrable EUDR compliance and traceability. A growing list of Geographical Indication (GI) and other protected products already showcases the diversity and quality of Thai agriculture and provides a foundation for differentiated, high‑value market positioning.
Branding: Strong origin‑based branding that connects specific producing regions, farmer groups and quality attributes with verified deforestation‑free and legally compliant supply chains can enhance consumer trust and buyer confidence. Public agencies can support this by integrating compliance information into GI schemes and export promotion programs, and by facilitating joint branding initiatives between producer groups and exporters.
Price premiums and value retention: Premium products backed by fully traceable, compliant supply chains are better positioned to secure higher prices and longer‑term contracts in EU markets. This can translate into improved incomes for smallholder farmers and rural communities. To enable this, the state can prioritize support for compliance costs (e.g. mapping, documentation, digital systems) in high‑potential sectors such as specialty coffee, fine‑flavour cacao, and sustainably produced rubber, and ensure that value‑addition mechanisms are accessible to smallholders as well as larger enterprises.
Export resilience and market diversification: By meeting EUDR and related due diligence standards, Thailand can strengthen the resilience of its export portfolio to future regulatory shifts and trade disputes. Government action to align domestic standards with the EUDR and to systematically integrate traceability and legality requirements into trade and investment promotion can help safeguard existing market shares and open doors to new segments within the EU, including green public procurement and sustainability‑oriented buyers.
Regional leadership and cooperation: Thailand’s low‑risk status, experience with TH‑TLAS and RAOT registration, and early development of national traceability platforms position the country to play a leading role in regional efforts to build deforestation‑free and legally compliant supply chains. With targeted diplomatic and technical initiatives, the government can use this position to promote regional cooperation, share lessons with neighbouring countries, and attract investment into Thai systems and products as part of broader ASEAN–EU engagement on sustainable trade.
Together, these opportunities suggest that proactive state action to consolidate compliance systems, support smallholders, and integrate EUDR requirements into trade, branding and rural‑development policies can turn regulatory adaptation into a driver of export growth and rural prosperity.
Assessing Thailand’s Overall Readiness for EUDR
Governance and policy
Advanced: Thailand has clear political recognition of EUDR, a low‑risk classification, and long‑running FLEGT/TH‑TLAS reforms that provide a solid legal foundation.
Data and systems
Partial: The national EUDR traceability platform and sectoral systems (TH‑TLAS, RAOT/TRT) are promising but remain in the early stages of scaling and integration. As Thailand expands digital traceability, it will also need clear data governance rules to protect producers' information, ensure lawful data sharing, and align domestic privacy requirements with the information needs of EU buyers and regulators.
Smallholder inclusion
Lagging: Smallholders dominate production but face persistent gaps in geolocation, documentation, and digital access despite early pilots.
Market positioning
Emerging: Thailand can leverage low‑risk status, specialty products, and strong branding to position itself as a regional EUDR‑ready hub if it closes smallholder and data gaps.
Thailand is relatively well-positioned to meet EUDR requirements, particularly at the policy and systems levels. Still, full readiness will depend on how quickly the country can scale up plot-level traceability, strengthen land rights documentation and integrate public and private data systems. The most important next step is to convert current pilots into interoperable national mechanisms that are inclusive of smallholders and usable by exporters, regulators, and EU buyers alike.
©Tim Morch, 2026
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