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This regulation has been under intense debate since its adoption in 2023, with various supplementary documents published to refine, adjust, and clarify expectations for companies. The most recent update was published on 4 May 2026.
Deforestation is a key driver of global CO₂ emissions. Land‑use change, including deforestation, is responsible for 12 to 20 percent of global greenhouse gas emissions. In 2017, Europe accounted for approximately 16 percent of deforestation linked to international trade, making EU trade and consumption a significant global driver of deforestation.
The EUDR is a cornerstone regulation of the European Green Deal. Its objective is to ensure that key commodities entering and leaving the EU, such as cocoa, coffee, palm oil, soy, rubber, cattle, and wood, do not contribute to deforestation or forest degradation. Companies must trace their supply chains back to the origin and submit due diligence statements confirming compliance with deforestation‑free and legal production requirements before placing products on the EU market.
Most obligations apply to the “operator”, defined as the organisation that places an in‑scope product on the EU market. However, every subsequent company in the supply chain may also have obligations under the EUDR, referred to as “downstream operators” or “traders”. Small and medium‑sized enterprises (SMEs) are generally exempt from due diligence requirements but must still provide relevant information.
On 4 May 2026, the European Commission published several documents as part of a simplification review of the EUDR. These include an updated version of the Frequently Asked Questions (FAQ), revised guidance, a draft delegated act on the product scope of the EUDR, and an implementing act on the Information System for Member States. The most relevant updates are outlined below.
The enforcement starting dates remain unchanged. The regulation will apply from 30 December 2026 for large and medium‑sized operators, and from 30 June 2027 for SMEs and micro‑operators.
The updated FAQ introduces a new category of operators: the Micro or Small Primary Operator (MSPO). An MSPO is an individual or a micro or small undertaking within the meaning of Directive 2013/34, established in a low‑risk country, including all EU Member States, that places self‑produced products directly on the EU market or exports them.
For these operators, simplified obligations apply. An MSPO may submit a one‑time simplified declaration, use a postal address instead of geolocation data, and declare multiple products and plots in a single Simplified Declaration (SD), rather than submitting a full Due Diligence Statement (DDS).
The updated FAQ and guidance provide further clarification on due diligence‑related obligations of downstream operators and traders.
While these parties must keep detailed records of their direct business partners, they are only required to collect DDS reference numbers when they are aware that their direct supplier qualifies as an operator. Importantly, the obligation to provide this information rests with the upstream operator, not with the downstream operator or trader.
To comply with the duty to collect and retain information, it is sufficient for downstream operators and traders to be able to retrieve and compile the relevant data within a reasonable period following a request from a competent authority or in the event of substantiated concerns. Collected data must be retained for five years.
Downstream operators and traders must notify authorities and business partners if substantiated concerns arise. This is a reactive obligation; there is no proactive duty to investigate the entire upstream supply chain. In practice, this means the obligation is triggered only when indicators of non‑compliance are communicated to the company. A clear presumption of good faith applies.
Non‑SME downstream operators and traders are additionally required to register in the Information System.
The updated FAQ introduces a formal definition of substantiated concerns. These are duly reasoned claims based on objective and verifiable information indicating non‑compliance with the regulation. When a downstream actor becomes aware of such concerns, whether through public authorities or private entities, it must immediately notify the competent authorities. Non‑SME companies must also stop placing the product concerned on the EU market.
The FAQ further clarifies the evidentiary standards and provides guidance on whistleblower protection.
The update places increased emphasis on the TRACES‑based Information System, which is being prepared for enhanced functionality across global supply chains. Key developments include:
A dedicated interface enables Micro and Small Primary Operators, primarily targeting EU smallholders, to submit a one‑time simplified declaration instead of recurring Due Diligence Statements. The system allows the use of postal addresses instead of precise geolocation data. This option does not generally apply to third‑country smallholders, as they typically do not act as the operator placing goods on the EU market.
To address fragmented shipments, such as rubber and cattle, the system allows multiple upstream DDS reference numbers to be linked. Despite this functionality, operators remain responsible for collecting and transferring potentially thousands of reference numbers per shipment, which continues to represent a significant administrative burden.
The Commission provides automated web services that enable corporate ERP systems to connect directly with the Information System. This functionality is essential for high‑volume traders that must include DDS reference numbers in customs declarations for product release.
Although the Commission is working to integrate national data sources to support compliance, operators remain legally responsible for verifying that products comply with the legislation of the country of production. This includes laws on land use, human rights, and anti‑corruption.
Through a draft delegated act, the Commission has proposed targeted amendments to the product scope of the EUDR.
Before the delegated act can enter into force, the Commission must complete a 30‑day public consultation. The Council and the European Parliament then have a 60‑day period to approve or reject the act.
The updated documents reconfirm both the obligations and the timeline, underscoring the need for companies to move forward at full speed. Once the regulation enters into force at the end of the year, companies must be able to demonstrate deforestation‑free supply chains. Key actions include:
Mapping your supply chain provides critical insight into deforestation risks and helps identify high‑risk areas. Beyond regulatory compliance, detailed supply‑chain mapping supports broader ESG objectives, such as emissions reduction and value‑chain impact assessments.
Assess supplier readiness and collaborate to improve traceability and data quality. This approach enables a more agile response to regulatory developments and helps reduce risk in an environment of legal uncertainty.
Align EUDR compliance with wider sustainability and business strategies. This allows regulatory requirements to be transformed into opportunities for long‑term value creation and competitive advantage.
Need help or would you like to learn more about the EUDR and its impact on your organisation? Feel free to call or email our experts. We are happy to support you.
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