The EUDR Clock Is Running: What the Commission's May 2026 Review Means for You
On 4 May 2026, the European Commission published its long-awaited review of the EU Deforestation Regulation (EUDR) simplification measures, fulfilling a mandate under the December 2025 amendment. This report responds to extensive feedback from various sectors that have been raising concerns about the broader impact of EUDR on business operations. According to the Commission, this review estimates an approximately 75% reduction in annual compliance costs from the cumulative simplification of measures introduced since 2023. To preserve legal certainty and maintain a stable regulatory framework, the Commission has determined that no further amendment to the basic legal text is warranted at this time.
The Commission’s report confirms there will be no further delays in implementation. Compliance deadlines remain 30 December 2026 for large and medium operators, and 30 June 2027 for most micro and small operators (MSPOs). (Those covered by the EU Timber Regulation [EUTR] must meet the December 2026 deadline. We offer a more in-depth explanation and comparison of EUDR and EUTR here.) Accompanying the report, the Commission also released an updated Guidance Document for Regulation (EU) 2023/1115 on Deforestation-Free Products and a fifth iteration of its implementation FAQs, both of which clarify how the amended rules apply in practice. Below, we walk you through some of the biggest changes to come from the EU’s latest report on EUDR.
THE ROLE OF CERTIFICATIONS AND THIRD-PARTY VERIFICATION SCHEMES IN RISK ASSESSMENT AND RISK MITIGATION
Section 10 of the updated Guidance Document is dedicated to contextualizing the role of certifications and third-party verification schemes, which may support compliance and risk assessment by corroborating that products are legal and deforestation-free. The Commission recognizes that both certifications and third-party verified schemes “can play an important role in promoting sustainable agricultural and forestry practices and responsible sourcing, in fostering supply chain transparency and in facilitating compliance.”
According to Section 10 of the Guidance Document (“The Role of Certifications and Third-Party Verification Schemes in Risk Assessment and Risk Mitigation”), the Commission intends to establish “planned trade facilitation tools” that will enable trade and support compliance with EUDR. This includes developing a repository of certification schemes to “provide transparent information on the scope of existing schemes.” Economic operators may refer to this repository when implementing their due diligence for and getting products into the EU market. The repository is expected to be available by December 2026.
The Commission acknowledges that, although these certification schemes can support risk assessment as outlined in Article 10 of the EUDR regulation, no individual certification scheme can replace the mandatory due diligence that EUDR calls for in Section 8 of the Guidance Document (entitled “Regular Maintenance of a Due Diligence System”). Before deciding to become certified against any specific scheme, the Commission advises that operators first ensure the certification will be aligned with EUDR. An extensive vetting process is recommended, and the Commission outlines a number of considerations in Section 10 of the Guidance Document.
As we mentioned, December 2026 marks when this repository of relevant certification and third-party verification schemes will be available. In the meantime, the Commission encourages operators to consult three different documents: the Commission’s Impact Assessment; the EU best practice guidelines for voluntary certification schemes for agricultural products; and the findings of the Commission’s Study on Certification and Verification Schemes in the Forest Sector for Wood-based Products.
RE-IMPORTS: WHAT THE UPDATED GUIDANCE AND FAQ MEAN FOR NON-EU OPERATORS
For operators outside the EU who handle products that were previously placed on the EU market, the updated FAQs (FAQ 5.4) provide a meaningful simplification. Re-importing such products is now explicitly classified as a downstream activity, meaning that the re-importer is not required to submit a new due diligence statement, provided they can demonstrate that the product was previously placed on the EU market.
Acceptable evidence includes customs declarations, invoices, bills of lading, CMR transport documents for road shipments, delivery notes, and any other reliable business records that relate to the product. Where no due diligence statement (DDS) reference number was received from a supplier, a conventional reference number is available for use in the customs declaration. Note that Competent Authorities are informed when a conventional reference number is used and may follow up accordingly. If prior EU market placement cannot be demonstrated, full due diligence obligations apply.
ADDITIONAL CHANGES: UPDATED GUIDANCE & FAQS CLARIFICATIONS
The Version 5 FAQ from April 2026 also introduces several entirely new provisions that address scenarios not previously covered:
E-commerce and online sales (FAQ 3.17–3.19): EUDR applies to all commercial online sales, whether B2B or B2C, regardless of whether the seller is established in the EU. The FAQ clarifies how roles (upstream operator, downstream operator, trader) are assigned in online supply chains, including for marketplaces and fulfillment providers. EU consumers purchasing for personal use remain exempt, but the commercial actor supplying them is not.
Dual role: operator and downstream operator (FAQ 3.8): A single company can be both an upstream operator and a downstream operator for the same product in the same supply chain. This applies, for example, to a company that imports a relevant commodity and processes it before selling: It holds an operator role for the processed product and may simultaneously hold a downstream role for other products in the same chain.
Cooperatives and associations as authorized representatives (FAQ 3.20): Cooperatives, associations, and similar bodies may submit due diligence statements or simplified declarations on behalf of their members, acting as authorized representatives. This is particularly relevant for micro and small primary operators (MSPO) supply chains, where individual submissions would be impractical. The authorized representative must be established in the EU; legal responsibility for compliance remains with the individual operator.
Downstream operators and substantiated concerns (FAQ 3.6.2): New guidance clarifies what non-SME downstream operators must do when they become aware of a substantiated concern or information indicating non-compliance. The obligation is reactive; it does not require systematic monitoring, but once triggered, the non-SME downstream operator must verify that due diligence was exercised and must not continue to place the product on the market until satisfied that no or only negligible risk exists.
The most important document that organizations should be familiar with is the Guidance Document for Regulation (EU) 2023/1115 on Deforestation-Free Products (Updated 4 May 2026).
For easy access to the most common questions, we recommend the Updated FAQs on EUDR Implementation (Version 5, April 2026).
What’s In and What’s Out: The Draft Delegated Act on Product Scope
The draft Delegated Act on Product Scope released in May 2026 proposes to update Annex I to edit the list of relevant products subject to EUDR and clarify how the regulation applies in specific cases and categories of products. Essentially, the proposed updated Annex I adds and removes commodities to ensure products fall within the proper scope of the regulation and without the risk of “relocating” the source of deforestation to unregulated segments of the supply chain.
Some of EUDR’s proposed additions to the list of in-scope products are palm oil derivatives, including soap made with palm oil, certain oleochemicals, and soluble coffee. Soluble coffee is an interesting case because, while roasted and green coffee beans have been included under EUDR, soluble coffee has not been previously included. This former exclusion resulted in what the report identifies as “a fragmented and incoherent approach for the coffee sector” that, in past versions of EUDR, may have resulted in relevant products being “placed on or exported from the Union market without complying with the obligations of Regulation” (see the Draft Delegated Regulation). The proposed updated Annex 1 now includes soluble coffee to repair this fragmentation, subject to adoption.
This EUDR update also proposes product exclusions under the draft updated Annex 1. Broader and spanning multiple categories of EUDR commodities, the proposed exclusions include leather and cattle hides; retreaded tyres; waste, used, and second-hand products; product samples and items used for testing or analysis; items of correspondence; and certain packaging materials.
The draft Delegated Act's proposed exclusion of leather and cattle hides has drawn organized feedback during the consultation period, which closed 1 June 2026, with campaigns both supporting and opposing the proposal. Industry arguments in favor of exclusion cite scientific evidence of a weak causal link between leather production and deforestation, with leather cited as being a low-value byproduct of the food industry. Industry arguments also raise concerns about disproportionate compliance burdens and competitive disadvantage for EU tanneries relative to non-EU suppliers.
Opposing voices argue that leather's inclusion is essential to preventing the relocation of deforestation risk within the cattle supply chain. The geographic distribution of responses, with Germany and France together accounting for nearly two-thirds of all feedback and Brazil (the world's largest leather exporter) ranking fourth, suggests the leather question will be among the most contested elements of the final act.
If adopted, the proposed additions will bring new companies into scope, particularly in consumer goods and chemicals, which currently have no direct EUDR obligations. To follow the progress of act adoption, you can visit the commission’s Draft Delegation Regulation page.
Key Changes from the December 2025 Amendments (Regulation (EU) 2025/2650)
The May 2026 package analyzes the impact of structural changes that were introduced when Regulation (EU) 2025/2650 was published on 23 December 2025. In the following sections, we offer a high-level overview of the biggest changes brought by this latest update.
NEW DOWNSTREAM OPERATOR CATEGORY
The amended regulation introduces a new category of “downstream operator”: entities placing products on the market that were manufactured using products already covered by a due diligence statement or simplified declaration. Downstream operators and traders that are not SMEs are no longer required to carry out full due diligence for every product they place on the market, sell, or export, although they must still register in the EUDR Information System. Only the first downstream operator in a chain is required to collect and retain DDS reference numbers.
MICRO AND SMALL PRIMARY OPERATORS (MSPOS) & SIMPLIFIED DECLARATIONS
A new subcategory of “micro and small primary operators” has been created. An operator qualifies as an MSPO if they are an individual or a micro/small business based in a low-risk country, and they place on the EU market, or export, products that they produce themselves. MSPOs may submit a one-time simplified declaration in the Information System rather than a full due diligence statement; they may also replace GPS geolocation coordinates with the postal address of the plots of land or the establishments from which the relevant commodities were produced, provided that the address corresponds to the actual production location.
PRINTED PRODUCTS REMOVED FROM SCOPE
Printed products have been removed from the scope of the EUDR. These include printed books, newspapers, images, and other products of the printing industry, manuscripts, typescripts, and plans on paper. This was enacted by Regulation (EU) 2025/2650 and is not subject to the ongoing Delegated Act consultation. Note that wood pulp and paper products under HS Chapters 47 and 48 (of the EUDR Annex) remain in scope where they contain virgin wood fiber.
FIVE-YEAR RECORD RETENTION FOR ALL OPERATORS
Regardless of size, all operators must collect and retain for five years data on the operators, downstream operators, or traders who have supplied them with relevant products, as well as details of downstream operators or traders to whom they have supplied relevant products.
INFORMATION SYSTEM UPDATES
The EUDR Information System, established under Article 33 of the Regulation, is the Commission-operated platform through which operators submit DDS and simplified declarations before placing relevant products on the EU market or exporting them. Launched in December 2024, the system also serves as a registry accessible to downstream supply chain actors and Competent Authorities for verification and enforcement purposes. The DDS reference number generated by the system must be included in customs declarations for products entering or leaving the EU, making the system a direct link between EUDR compliance and customs clearance.
The Commission temporarily closed the Information System to integrate changes required by the December 2025 amendment. A staged reopening is planned for June 2026 (both training and production environments), with additional functionalities to follow in summer 2026 ahead of the EUDR December 2026 implementation date. Key updates being introduced can be understood across six categories, which we discuss below.
Simplified declarations: The system will support submission of MSPOs’ one-off simplified declarations, including via API. This is significant because the simplified declaration workflow is entirely new. MSPOs were not previously accommodated in the system at all, and downstream actors receiving declaration identifiers from MSPOs will now be able to verify them in the same way they verify standard DDS reference numbers.
New operator roles: Registration categories for MSPOs and non-SME downstream operators/traders are being added. Under the December 2025 amendment, non-SME downstream operators are required to register in the system even though they no longer submit DDS. This update creates the technical infrastructure to accommodate that obligation.
Voluntary grouping: Operators will be able to voluntarily group DDS reference numbers, reducing administrative burden for those managing multiple upstream suppliers. This feature was specifically requested by industry and addresses a practical pain point for operators who receive large volumes of DDS reference numbers from different upstream sources and need to pass them downstream efficiently.
Validity checking: Users will be able to verify the validity of DDS reference numbers and declaration identifiers directly within the system, including via CSV file upload for bulk checking. This is particularly useful for the first downstream operator in a chain, who has a legal obligation to collect and retain valid reference numbers.
Geolocation support: Updated tools will be launched to assist Member State Competent Authorities in analyzing geolocation data submitted by operators. The update also reflects revised guidance on geolocation alternatives, including the postal address option now available to some MSPOs in lieu of GPS coordinates.
Contingency arrangements: Updated webservice specifications will mirror existing system functionalities and contingency procedures in the event of system unavailability. Given that DDS submission is a prerequisite for customs clearance, system downtime carries direct operational risk for operators. These arrangements are intended to ensure compliance obligations can continue to be met even during outages.
Are You Ready for EUDR?
To learn more, please visit our website: European Union Deforestation Regulation (EUDR) Support | SCS Global Services. You can also take our quick EUDR readiness check. Or, if you’d like more support, you can contact our EUDR team directly: [email protected].
