The recent EU vote, held just before the winter holidays and only days before the original go-live date, has resulted in a further 12-month deferral and a significant refocus for EUDR compliance. The border is now the central control point, placing importers firmly in the spotlight. The core objective of the law has not changed though : no product may be placed on the EU market or exported unless it is deforestation-free, legal, and covered by due diligence.
What Has Changed?
New Important Dates
- By 30 April 2026 the EU Commission needs to carry out a ‘simplification’ review of the amended EUDR regulation, and if necessary, propose additional changes to the rules
- For now, the main EUDR obligations are postponed for one year and will take effect from 30 December 2026
- For micro and small operators as well as natural persons, established by 31 December 2024, the obligations are also postponed by one year and will begin on 30 June 2027
- The customs Single Window interface should go live by 1 December 2029
Micro/Small Primary Operators (Low-Risk)
- For farmers and other small operators a new subcategory is introduced : ‘micro or small primary operators’. This subcategory should cover natural persons or micro or small enterprises established in a country classified as low risk, that place relevant products on the market or export those products which they themselves produce in that country.
- These operators may submit a one-time simplified declaration in the system to obtain a Declaration Identifier (DI), which is equivalent to a Due Diligence Statement (DDS) for this category.
- In this ‘simplified declaration’, these operators can replace the geolocation of plots of land by the postal address of the plots of land or of the establishment where the relevant commodities were produced.
- If all required information for a micro or small primary operator already exists in Union or Member State databases and is made available to the EUDR system, the operator is not required to submit the one‑time simplified declaration, but the DI will be generated based on the available information.
Downstream Obligations Simplified
- The rules for ‘operators’ remain unchanged, but another new EUDR category has been introduced: the ‘downstream operator’. Their obligations are identical to the ‘trader’. This downstream operator places on the market or exports EUDR products that are already covered by a ‘DDS’ or ‘DI’ earlier in the supply chain.
- The obligation to ensure full traceability by collecting reference numbers of DDS’s or DI’s only applies to the first downstream operator or trader in the supply chain (tier 1), regardless of enterprise size. This obligation no longer applies to other downstream operators or traders further down the supply chain.
- Non-SME downstream operators and traders must still register in the information system, and keep records of their suppliers and customers.
- Where there are “substantiated concerns”, non‑SME downstream operators/traders still have to verify that due diligence was exercised and that no or only negligible risk was found before proceeding to trade or export.
- Downstream operators who export an EUDR product, are no longer required to present a DDS or DI at the border.
Printed paper products out of scope
- Printed paper products have been removed from Annex I. The line “ex 49 Printed books, newspapers, pictures and other products of the printing industry, manuscripts, typescripts and plans, of paper” is deleted, meaning these items are no longer in scope.
Border Impacts: What Importers Must Get Right
- Ensure CN/TARIC codes, net mass, and supplementary units are correct, and that a valid DDS reference or DI is available.
- Supplier documents, DDS entries, and customs declarations must align on codes, quantities, origins, and parties to prevent holds.
- Confirm the importer of record and operator for each trade lane, including DDP shipments.
- Update standard operating procedures (SOPs) to reflect the simplified regime.
- Plan automation to ensure DDS references and DI’s flow seamlessly into declarations, with authority messages feeding back accordingly.
- Prioritise low-risk sourcing where possible and institute controls to prevent mixing or circumvention.
- Segregate or clearly tag transitional versus post-application goods and maintain evidence of placement dates.
Key Takeaways
- Compliance will ultimately be determined and tested at the border.
- The 12-month extension offers a chance to reset focus, not to pause preparation.
- Use this period to:
- (Re-)confirm importers of record and operators for each trade lane
- Implement robust border-first control measures
- Update SOPs to reflect the new rules
- Map out your IT roadmap in preparation for the Single Window system
- Segment (transitional) stocks with a view to low-risk sourcing
- Test your readiness and identify opportunities for process optimisation through an external review of your EUDR management system
For further information about EUDR, please visit our website or contact your PwC person: Jochen Vincke, Giovanni Gijsels, Colin Metzler, Helena Caluwé, Marvin Yabili
