Blog 15 min read

EUDR Simplification Review 2026: What’s New, What Stays the Same, and What Additional Support Can Companies Expect?

May 12, 2026 EUDR Simplification Review 2026: What’s New, What Stays the Same, and What Additional Support Can Companies Expect?

This blog was originally posted on 12th May, 2026. Further regulatory developments may have occurred after publication. To keep up-to-date with the latest compliance news, sign up to our newsletter.

AUTHORED BY HANNAH JANKNECHT, SENIOR REGULATORY COMPLIANCE SPECIALIST, AND KAYLEIGH DUANE, REGULATORY COMPLIANCE ANALYSTCOMPLIANCE & RISKS


Key Insight

The EU Commission’s 2026 simplification package aims to reduce EUDR compliance costs by 75% compared to previous estimates from 2023. The Commission has updated the relevant guidance documents and proposes new support tools while maintaining the original implementation deadlines. Significant proposed changes include adjusting the product scope to exclude leather and retreaded tyres while adding soluble coffee and certain palm oil derivatives.

Introduction

On 4 May 2026, the EU Commission released its simplification package of the EU Deforestation Regulation (EUDR), as agreed under the regulation’s revision in December 2025. The package consists of a simplification report, reviewing the measures introduced since 2023, updated EUDR guidance, and a draft delegated act proposing to refine the list of products in scope of the EUDR. The Commission estimates that these simplification measures will reduce the annual compliance costs for companies by approximately 75% compared to the original estimates from 2023. While the simplification package is designed to support and facilitate the implementation of the EUDR without making significant changes to the core legal framework, the draft delegated act contains some surprising suggestions regarding the product scope. 

This blog examines the proposed changes to the product scope, the updated supporting documents and potential further measures on the horizon. 

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Are There Any Changes to the EUDR Timeline and Product Scope?

The simplification package confirmed that the application of the EUDR timeline remains as agreed under the amending Regulation (EU) 2025/2650 from December 2025:

  • 30 December 2026: Application of the EUDR for large and medium-sized companies,
  • 30 June 2027: Application of the EUDR for small and micro enterprises

The classification of medium, small, and micro enterprises follows the definitions provided in the Accounting Directive 2013/34/EU.

While the EUDR will become applicable as planned, the EU Commission proposed changes to the products in scope in a draft delegated act. This draft delegated act is not entirely new, but rather updates a previous proposal from April 2025. 

Proposed additions to the scope are soluble coffee and certain palm oil derivatives. Proposed exclusions and exemptions include leather products including raw bovine hides/skins (HS ex 4101), tanned/crust hides (ex 4104), further prepared leather (ex 4107) and retreaded tyres. 

The proposed exclusion of leather products has received mixed reactions from stakeholders. While some stakeholders have expressed their agreement with the exclusion of leather products as they believe leather is not a driver, but rather a by-product of deforestation, others, including the non-profit earthsight, note that leather used in Europe is closely linked to illegal deforestation and violations of Indigenous land rights in the Brazilian Amazon and Paraguayan Chaco. 

This Draft is open for consultation until 1 June 2026.

What Tools and Support Is the Commission Planning to Provide in the Coming Months?

The simplification report points out plans for several new support initiatives to facilitate compliance with the EU Deforestation Regulation (EUDR). 

Based on Article 3 of the EUDR, commodities and products must not only be deforestation-free, but also be compliant with the relevant laws of the country of production. ‘Relevant legislation of the country of production’ is defined broadly as the laws concerning the legal status of the area of production in terms of land use rights, environmental protection, forest-related rules, third parties’ rights, labour rights, human rights protected under international law, the principle of free, prior and informed consent (FPIC), tax, anti-corruption, trade and customs regulations. 

This broad definition is currently posing significant challenges for companies, who struggle to identify the applicable legislation of each country. To support companies in navigating the relevant laws, the EU Commission intends to establish a centralized list of relevant national legislation from the countries of production. 

In addition, the Commission is planning to set up a database of certification or third-party verified schemes applicable to EUDR commodities. While these do not replace due diligence, they are intended to facilitate risk assessments. 

Both databases will be hosted on dedicated websites. Information will be provided by third-country governments and owners of certification schemes using Commission-provided templates. The Commission plans to launch both repositories before the application of the EUDR in December 2026.

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Has the Commission Updated the EUDR FAQ and Guidance Document yet?

The European Commission has released several resources, including a guidance document (Commission Notice C/2025/3588) and a series of frequently asked questions, to help operators and traders prepare for compliance with the EUDR. Following the simplification measures introduced by Regulation (EU) 2025/2650, these documents have now been updated to clarify the new distribution of responsibilities between the initial upstream operator and downstream operators or traders. 

The FAQ document has been updated with information on:

  • Obligations for Downstream Operators and Traders: In accordance with the revised regulation, downstream operators and traders primarily collect and keep information about partners and DDS reference numbers instead of conducting due diligence themselves. In-depth explanations of their responsibilities can be found in Part 3 of the FAQ document. This includes new sections on how to identify supply chain roles, how to correctly communicate verification numbers to clients, and the steps downstream actors must take to remain compliant. 
  • Online Sales: Further information has also been added regarding the application of the EUDR in online sales. Question 3.17 and 3.18 clarify that the Regulation applies to all online or distance sales made in the course of a commercial activity, regardless of whether the buyer is a business or a private consumer. Marketplaces that only facilitate agreements without intervening in the actual supply are considered intermediary service providers with no EUDR obligations. However, if they provide fulfillment services or sell products themselves, they may be classified as operators or traders. Products strictly intended for private use or consumption (e.g., vacation souvenirs or parcels between relatives) are not covered by the EUDR. 
  • Primary Micro and Small Operators and Traders: An operator that is a natural person or a micro or small undertaking, established in a low-risk country, and placing products they produced themselves directly on the EU market. Instead of a full Due Diligence Statement (DDS), these actors submit a one-time simplified declaration. According to the FAQ, they may use their postal address instead of geolocation coordinates if it clearly corresponds to the plot of land or establishment where the products were produced. 
  • Interaction with other EU legislation: Companies already reporting value chain due diligence under the Corporate Sustainability Reporting Directive (CSRD) or Corporate Sustainability Due Diligence Directive (CSDDD) do not have to repeat the reporting for EUDR annual reports under Article 12 (3) of the EUDR. In addition, while the scope differs, the information collection, risk assessment, and mitigation steps taken for EUDR compliance can be used to support obligations under the Corporate Sustainability Due Diligence Directive (CSDDD) and the Forced Labour Regulation (FLR), as explained in question 5.1.1.

The updated guidance document provides additional practical examples to illustrate in particular the new distribution of responsibilities in the supply chain. Another supporting document, the EUDR supply chain infographics (3rd edition), was already updated in line with the revised regulation on 28 April 2026.

What’s Next?

Despite the recent simplification measures, the core message for businesses remains clear: the implementation timeline remains unchanged. Companies are urged to continue their preparations and align their internal operations immediately to meet the looming deadlines.

The deadline for submitting comments on the Draft Delegated Act is 1 June 2026. Stakeholders are encouraged to provide feedback on the proposed additions and exclusions before the text is finalised.

The Commission is actively refining the EUDR Information System to reflect the revised regulation and enhance user experience. Companies should closely monitor the roll-out of these technical updates and take advantage of upcoming support tools.

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