EU Deforestation Regulation (EUDR): Key Updates from the Simplification Review
The European Commission has published the expected simplification review on the EU Deforestation Regulation (EUDR), its landmark law on deforestation-free European consumption. The application deadline for large and medium sized companies is confirmed for 30 December 2026. The published documents, a Simplification Review Report, updated Guidance, updated FAQs and a draft Delegated Regulation on product scope, specifically provide clarity around the changes that came into effect in December 2025.
Key take-away: companies are now in the final stretch towards the 30 December 2026 application deadline, with clear guidelines available. No more delays, yet much work to do.
Key Updates
EU Deforestation Regulation Scope
The EUDR targets specific high-risk commodities including cattle, cocoa, coffee, palm oil, soy, and rubber and their derived products. The draft Delegated Regulation proposes scope changes for some of these derived products:
Exemption for sample products and products intended for examination, analysis and testing,
Removal of hides, skins and leather from scope,
Adding HS Code ‘2101 11 00 Extracts, essences and concentrates of coffee’ to the scope,
Adding oleochemicals derived from palm oil to the scope,
Exemption for retreaded tires.
Printed products (ex 49) were previously removed from scope. The draft will be open for public consultation and feedback until 1 June 2026.
Updated Guidance and FAQs
The fifth iteration of FAQs and an updated Guidance Document address recurring implementation questions and clarifications around the changes from December 2025. Key clarifications include:
Roles & Definitions
Updated outline of who is who in the EUDR
Operator: anyone first placing a relevant commodity/product (HS codes in Annex I) on the EU market or exporting it. This includes importers (release for free circulation) and domestic producers selling for the first time.
Micro/Small primary operators (MSPOs): natural persons or micro/small undertakings in low-risk countries who produce and place their own products on the market. They benefit from a simplified regime (one-off “simplified declaration,” can use postal address instead of geolocation).
Downstream operators: those placing on the market or exporting relevant products made from other relevant products that are already covered by a DDS or SD. Obligations are limited (info-collection, reporting, and in cases of “substantiated concerns,” a reactive check).
Traders: any other supply-chain actors making relevant products available to their clients (collect and keep supplier info, non-SMEs must register on Traces, reactive reporting/verification on substantiated concerns).
Traceability Always
Traceability requirements apply to each batch of imported/exported/traded relevant commodities. Composite products: only the main relevant commodity (Annex I) must be geolocated and assessed.
Risk Assessment Criteria
While simplified due diligence applies to products from low-risk countries of production, the concept ‘substantiated concern’ is prominent in the updated documents. In addition, any known country-level concerns, such as corruption, warrant further scrutiny, even for low-risk countries.
Transitional Stocks
Clarification on how companies can deal with stocks during the transitional period:
Commodities/products placed on the EU market during the transitional period (29 Jun 2023–30 Dec 2026/30 Jun 2027) are exempt. Derived goods using only those stocks remain exempt.
If goods mix exempt stocks with post-transition compliant stocks, only the latter need a DDS/SD (plus proof of pre-transition placement for the former).
Exporters vs downstream operators: exporters must show DDS ref. numbers; non-SME downstream exporters use a TARIC code exemption.
Re-import and Export
Clarification regarding re-import and export
Re-imports of EU-exported products: When you re-import a product you previously exported, you are treated as a “downstream operator” if you can prove the goods were already placed on the EU market and compliant with EUDR before export.
Exports from the EU: EU-based exporters of a relevant product are either an “operator” (if they place the product on the market for the first time) or a “downstream operator” (if they re-export a product already placed on the market by another EU operator). Operators must include their DDS reference number in the customs export declaration. Downstream operators instead use a dedicated TARIC code that exempts them from sending a DDS number at export.
Certification Standards
Operators may use credible, third-party verified or certified evidence to support legality & deforestation-free claims, provided the scheme’s standards, audit processes, chain of custody (no mass balance), and governance align with EUDR requirements. Schemes must explicitly cover EUDR HS codes, geolocation, cut-off date (31 Dec 2020), traceability, deforestation-free definition; mass balance or mixing with unknown origin is not acceptable.
Information System
The EUDR Information System (TRACES) was taken down mid-February of this year, to integrate changes as per the changes from December 2025. This, for example, covers the development of the Simplified Declaration for MSPOs. The system should reopen again in June 2026.
Coming Up
The Commission has also said they will create two repositories, aimed at supporting both competent authorities and operators:
one repository listing relevant legislation of the country of production, and
one repository on certifications schemes applicable to EUDR-relevant commodities
These should be in place prior to the application deadline of 30 December 2026.
What Companies Must Do Now
Assess Scope: Determine which products and suppliers fall within EUDR requirements
Establish Due Diligence Systems: Implement processes to identify and mitigate deforestation risks
Engage Suppliers: Communicate expectations and support suppliers in meeting requirements, particularly in developing markets
Map Supply Chains and Trace Products: Document the origin and production location of all covered commodities
Collect Documentation: Gather geolocation data, certifications, and evidence of compliance from suppliers
Assess and Mitigate Risk: Assess the collected data and documentation for EUDR compliance
Monitor Compliance: Establish internal controls and audit mechanisms to ensure ongoing adherence
How QIMA Can Help
The EUDR represents a fundamental shift in how the EU regulates imported products, placing sustainability accountability squarely on business operators. While the EU Deforestation regulation presents implementation challenges, particularly for smaller companies and those in data-sparse regions, it reflects global momentum toward sustainable sourcing. Companies that proactively address EUDR requirements can transform compliance into a competitive advantage, strengthening supply chain resilience and aligning with investor and consumer expectations for responsible sourcing.
Read the QIMA EU Deforestation Regulation (EUDR) Quick Guide for Companies to get practical insights how to comply with the EUDR.
Please contact QIMA to understand how we can help your company with end-to-end EUDR Services.
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