Explore the finalized transition periods and administrative reliefs for low-risk imports and MSMEs under the latest European Commission guidelines.
Even though we previously touched on the latest changes and clarification in regards to EUDR, there appears to be some ambiguity we left unaddressed. This publication goes in more depth about all the tweaks and changes that the Commission has adopted and fully follows its guidelines. As much as this resource will help operators and traders nail down their scope and obligations, there will always be something unclear about your EUDR compliance, so make sure to send us a message if you need help.
We will be hosting yet another EUDR webinar on the 22nd of July (BG only), so do join us. And if you would like us to do one in English too, let us know. We are totally up for it.
Following the postponement of the EU Deforestation Regulation (EUDR) in November 2025, a window was opened for its revision. This legislative process has finally concluded, and the traceability requirements are now definitively established. This article provides an overview of the updated scope and outlines how your business can potentially qualify for the newly introduced administrative relief.
Implementation Timeline and Scope
The compliance deadlines are strictly tied to the size of the enterprise. Large and medium-sized enterprises must fully comply by December 30, 2026, while micro and small enterprises (MSMEs) benefit from an extended transition period lasting until June 30, 2027.
The regulation universally governs seven primary commodities—cattle, cocoa, coffee, oil palm, rubber, soya, and wood—as well as their numerous derived products. Responsibility across the supply chain is determined by an operator's specific role:
- Primary Producers and Importers of raw commodities (such as live cattle, soy beans, coffee beans, or raw timber) are strictly required to SUBMIT precise GPS data and a Due Diligence Statement (DDS).
- First-Stage Processors transforming these raw materials into primary derivatives (such as fresh meat, soybean meal, crude palm oil, or sawn wood) must CREATE a new DDS in the system.
- Downstream Manufacturers of complex or secondary products (such as chocolate, tires, printed paper, packaging, or furniture) are required to either CREATE a new DDS or COLLECT the reference DDS numbers from their upstream suppliers, depending on whether their specific customs code classifies them as operators or traders.
- Packaging Users across all sectors must actively COLLECT DDS numbers for any cartons, paper products, and labels utilized in their merchandise.
* Important Clarification: Due Diligence Statements are strictly required only upon a change of ownership that constitutes placing a product on the EU market or exporting it. For example, if a vertically integrated forestry or agricultural enterprise manages its own land and processes its own raw materials internally without any intermediary sale, a DDS is only required for the final products leaving the processing facility.
May 2026 Scope Refinements: Additions, Deletions, FAQs
The latest changes cleared up the technicalities regarding the “ex” before the HS codes in the Annex I product list. In customs nomenclature, this prefix explicitly confirms that a product sharing a broader Harmonized System (HS) code is only subject to the regulation if it is physically derived from one of the seven core commodities. Essentially, this clarification that was done through the updated FAQs on the Commission’s website makes sure that products that share HS codes with affected goods, such as synthetic rubber, bamboo, or coconut oil - fall entirely outside the scope of the regulation, sparing companies from unnecessary due diligence tracking.
There is also an extension to the Annex I list as the regulation now includes soluble (instant) coffee, extracts, and concentrates, resolving a fragmented approach that previously allowed processed coffee powders and syrups to bypass compliance. The scope has also been adjusted slightly for cattle to include frozen cattle tongues to align with fresh offal categories, as well as specific palm oil derivatives heavily utilized in the chemical and cosmetics industries, such as palm-based soap bars and flakes.
Surprisingly for some (certainly for me), and in a major victory for the fashion and automotive industries, the Commission deleted cattle hides, skins, and finished leather products from the scope. Furthermore, finished retreaded tires have been removed, narrowing the compliance focus strictly to the raw rubber tread compound used in the retreading process.
As previously, the EUDR scope entirely excludes product samples used for laboratory testing, waste streams, second-hand or used goods, and both single-use and reusable transit packaging from triggering independent tracking obligations.
Full Due Diligence Requirements
Under the standard framework, primary producers and importers bear the full administrative burden of proving that their commodities did not originate from land deforested or degraded after December 31, 2020. They must collect exact geolocation data for every single plot of land, farm, or pasture where the raw material was produced, alongside verifiable proof of compliance with local legislation. This entire dataset must be submitted via a Due Diligence Statement (DDS) within the EU's TRACES platform.
Downstream processors and traders must maintain an audit trail. Businesses acting as traders are obligated to collect and retain the DDS reference numbers from their suppliers for a minimum period of 5 years, establishing clear traceability regarding which specific raw material batches were incorporated into which final product batches. For downstream manufacturers acting as operators—meaning they substantially alter the product or its tariff classification—the process demands a comprehensive risk assessment and risk mitigation plan, which ultimately requires full traceability back to each individual farm or plot of origin.
The New Simplified Due Diligence Regime
The 2026 updates introduce a simplified framework specifically for supply chains originating from regions or countries classified by the European Commission as "low-risk". Under this simplified regime, primary producers are entirely exempt from the formal risk assessment and mitigation phases.
For downstream processors handling raw materials from low-risk origins that have not been flagged individually, the administrative process is significantly accelerated. They remain obligated to input supplier information and verified proof of origin into the EU portal, but they are completely spared from conducting a full risk evaluation or implementing mitigation plans.
It remains that for farms, pastures, and land plots measuring under 4 hectares, operators are no longer required to map out full polygonal boundaries. Instead, submitting a single GPS point coordinate is legally sufficient.
The new tweak to this is that micro-producers are permitted to provide a standard postal address in lieu of geographic coordinates. The EU Commission’s goal with this is to keep the core due diligence and traceability requirements intact, while preventing micro operators needing an entire management department.
To what extent this regime prevents downstream companies to accurately ensure no deforestation has occurred remains to be seen.
I trust this concise breakdown clarifies the specific EUDR obligations for your business, regardless of the sector you operate in. Should you have any questions or require further assistance navigating these compliance paths, I remain entirely at your disposal.