On 4 May 2026 the European Commission published its EUDR simplification package. Many businesses were hoping for further easing or another postponement, but neither is forthcoming. Overall, the fundamental urgency of the EUDR changes little. The obligations remain intact, but the administrative burden is reduced.
The simplification package brings together four components: a simplification report, updated FAQs, a draft delegated act amending Annex I, and a revised implementing regulation on the EUDR information system. It reduces the administrative burden that the EUDR imposed on businesses – with particular focus on micro and small operators.
These are the key changes:
1. Products covered by the EUDR: the seven core commodities – coffee, cocoa, palm oil, cattle, soy, wood and rubber – are retained, but the exact product scope is adjusted at various points. Palm oil-based soap and its derivatives, and instant coffee, are added.
The following are removed from scope: cattle leather, waste as defined in the Waste Framework Directive (WFD), used and second-hand rubber and wood products, paper correspondence and marketing material, and samples for research or testing.
Note: these amendments are a proposal and may still be adjusted before they are formally adopted.
2. Downstream operators: downstream operators are not required to carry out full due diligence and therefore do not need to submit their own Due Diligence Statement (DDS).
Their obligations vary according to size:
• Non-SME downstream operators and traders:
o They collect the reference numbers of the DDS or simplified statements from their direct suppliers and pass these on to the next actor in the chain.
o They must register in the EUDR information system before placing products on the market.
• SMEs as downstream operator or trader:
o They are not required to register in the EUDR information system, but must collect supplier reference numbers and maintain records of suppliers and customers.
o They are not obliged to submit a DDS themselves, but must be able to present information to the authorities on request.
For both categories, the role is more than administrative. Where there are indications of non-compliance in the chain, they must take appropriate measures, and they may be held liable for infringements.
3. Country risk classification: the benchmarking system will not be updated in 2026. All countries remain classified as standard risk for the time being. Due diligence obligations therefore apply in full for all countries of origin, with no further relief for low-risk countries.
4. Geolocation data requirements: the core obligation to provide plot-level geolocation data to guarantee traceability remains in place for operators placing products on the EU market for the first time. Micro and small primary operators submit a single, one-off simplified statement for their activities (rather than a DDS per shipment), and may use a postal address instead of precise plot information. For all other actors, the required geolocation precision remains unchanged.
Three essential elements of the EUDR remain unchanged:
The implementation timeline is tight. Businesses that have not yet taken a systematic approach have less than eight months to become operational. In practice, setting up traceability and documentation systems, mobilising suppliers and establishing internal processes takes six to nine months.
For the coming weeks, there are three priorities:
1. Confirm your scope – down to product level. Do you know with certainty which of your products and procurement components contain the seven EUDR commodities? And equally important: can you correctly determine yourrole in the chain – operator, downstream operator or trader? This directly determines your obligations. Also check whether the products you import or trade fall under the updated Annex I.
2. Map your value chain and suppliers – and start the data collection process. Do you already have geolocation data for the production sites of your critical suppliers? If not, this is the first priority. Identify which suppliers deliver EUDR-relevant commodities, determine who in your chain is the primary operator(the party placing products on the EU market first), and send out a structured data request. Bear in mind that suppliers outside the EU sometimes need severalmonths to retrieve plot information. Start these conversations now.
3. Carry out a baseline assessment and translate it into an implementation plan. Where do you stand today? What is already in order and what is still missing? Watch out for a common pitfall: businesses interpret the simplifications as areduction in obligations, when in reality it is primarily the administrativeform that changes, not the substantive requirements.
A baseline assessment gives you a clear picture ofthe way forward. From there, you can build a detailed implementation plan with clearlyassigned responsibilities, milestones and a timeline towards 30 December 2026 –so that you avoid being under time pressure in autumn.
→ Download our white paper EUDR after the revision: your route to compliance
