On 4 May 2026, the EU Commission published its simplification review of the EU Deforestation Regulation, together with a draft Delegated Act on product scope and updated FAQs (Version 5).
The review refines the product scope through a draft Delegated Act. Soluble coffee, certain palm oil derivatives and frozen cattle tongues are proposed for inclusion, while leather and rethreaded tyres are proposed for removal. In parallel, broad horizontal exemptions are introduced for waste, samples and packaging. Downstream obligations are also intended to become lighter, with a more passive compliance model under which only the first downstream operator must retain reference numbers.
According to the EU Commission, the simplification measures adopted since 2023, combined with the new package, are expected to reduce annual compliance costs by around 75%, from EUR 8.1 billion to EUR 2.0 billion. At the same time, the EUDR is expected to deliver environmental benefits of approximately EUR 7 billion per year by preventing 208,000 hectares of deforestation and 49 million tonnes of greenhouse gas emissions annually. The message is clear: the EU Commission does not intend to propose further legislative amendments and the EUDR is not being reopened.
Below is a summary of the key developments, what they mean in practice, and the actions companies should now prioritise.
What Has Changed?
Key dates for compliance confirmed
- 30 December 2026: Main EUDR obligations start for all companies, except micro and small operators
- 30 June 2027: Obligations start for micro and small enterprises
- June 2026: the EU Information System reopens (training and production environments) following temporary closure to deploy updates required by the December 2025 amendments
Product Scope Refined (Draft Delegated Act)
The EU Commission published a draft Delegated Act proposing targeted changes to the Annex I of the EUDR. The draft is open for a four-week public feedback period. The key changes are:
- Additional products in scope: Soluble coffee (HS 2101 11 00 – extracts, essences and concentrates of coffee) ; Certain palm oil derivatives used in the oleochemicals industry, including soap made with palm oil ; Frozen cattle tongues (HS ex 0206 21 00), aligning with fresh cattle tongues already in scope
- Products proposed for removal: Cattle skins, hides and leather (HS 4101, 4104, 4107), reflecting the differentiated leather value chain and limited leverage of EU operators over upstream cattle suppliers; Retreaded tyres (HS 40121100, 40121200,40121300, 40121900, 40129020,40129090) – the scope is narrowed so that only the new rubber tread (HS ex 4012 90 30) remains subject to obligations, recognising the circular economy rationale of retreading.
- Technical clarifications: Products made of bamboo, rattan and other materials of woody nature are explicitly confirmed as out of scope.
Micro or Small Primary Operators (MSPOs) – Further Relief
- The EU Commission further clarifies in the FAQ the definition of an MSPO through operational criteria: even a larger company may qualify where the business segment handling relevant commodities meets the micro or small primary operator thresholds.
- In addition to a postal address, cadastral information or equivalent identifiers that allow the plot of land or establishment to be identified may be used in place of geolocation.
- Cooperatives and associations may submit simplified declarations or DDS on behalf of their members as authorised representatives. Where the cooperative places products on the market itself, it may qualify as an operator or MSPO and submit a single declaration.
Simplified legality checks and Due Diligence obligations
- Operators sourcing from low-risk countries under simplified due diligence are not required to conduct risk assessment or mitigation unless they become aware of information indicating potential non-compliance.
- As MSPOs, by definition, source from low-risk countries, they are not required to conduct risk assessment or mitigation unless a specific risk is identified.
- The Commission further clarifies that operators may carry out an initial screening of available information, including public reports, country indicators and the Commission repository. Where this screening supports a negligible-risk conclusion, no further in-depth legality review is required.
Downstream Obligations Further Clarified
The updated Guidance and FAQs further clarifies the role of downstream operators and traders in the supply chain. Below we have listed some (non-exhaustive) examples:
Your situation |
What you must do |
What you don’t need to do |
| You buy directly from an operator (importer)
|
Collect & keep DDS reference numbers if your supplier sends them to you
|
Proactively ask for the DDS references, you can presume in good faith your supplier is not an upstream operator if you receive nothing
|
| You buy from another downstream actor
|
Collect & keep your business partners’ contact details (name, address, email) in your own records
|
Collect or keep any DDS reference numbers, this only applies one step below the operator
|
| You become aware of possible non-compliance
|
Inform the competent authority
|
Actively investigate your supply chain, this is a purely reactive obligation
|
| You import a product, transform it, and sell the new product (dual role)
|
Exercise due diligence at import/export (as operator) and develop the DDS.
|
Pass on your DDS reference number to the next buyer of your derived product
|
| You re-import a product previously placed on the EU market
|
Provide evidence of prior EU placement; use a conventional reference number at customs
|
Submit a new DDS
|
| You export a product covered by an existing DDS
|
Use the dedicated TARIC certificate code at customs
|
Present a DDS reference number at export
|
Call to Action: Time is running out!
- The 30 December 2026 deadline is firm. Use the remaining months to get compliant!
- The Information System reopens in June 2026. Prepare your IT systems and processes now.
- Two new repositories (legislation and certification schemes) will go live before end-2026 to support legality compliance. Investigate how these can be used for your company.
For further information about EUDR, please visit our website or contact Jochen Vincke, Giovanni Gijsels, Christoph Vanderstricht or Helena Caluwé.
