EUDR Simplification Package, May 4, 2026: What You Need to Know
On May 4, 2026, the Commission has published the long-awaited EUDR simplification package: a Report to Parliament and Council on the Commission's simplification efforts, the third edition of the Guidance document, the fifth iteration of the FAQs, and a draft Delegated Act on product scope (open for public feedback until 1 June). An updated Implementing Act on the Information System has been shared with Member State experts and is expected shortly.
The Commission resisted pressure to reopen the legal text to include zero-risk or negligible risk categories and has held the 30 December 2026 application date (30 June 2027 for most micro and small operators).
For companies preparing for implementation, six points are worth flagging:
It is further clarified with practical examples on how companies should determine whether they are operators, downstream operators or traders. Depending on the specific product flow and the transaction, the same entity can be an operator for one product, a downstream operator for another, and a trader for a third, which is a very important clarification for businesses with mixed supply chains (FAQ 3.8).
The first downstream operator role is lighter. The biggest practical improvement is for downstream operators and traders. The updated FAQs make clear that they do not need to proactively police their suppliers’ legal role or routinely redo upstream due diligence. If no DDS reference number is passed on, they may rely in good faith on the presumption that their supplier is not an upstream operator, unless they are aware of substantiated concerns. In most cases, the downstream role is now record-keeping, retention of direct business partner information for five years, and escalation if credible non-compliance concerns arise.
Re-imports can be handled as downstream activity (FAQ 5.4) where prior EU placing and due diligence are evidenced. A "conventional reference number" — to be communicated by the Commission — can be used at customs.
On product scope, the draft Delegated Act proposes some meaningful changes. Soluble coffee and additional palm oil derivatives would be added, while leather would be removed, and exclusions are clarified for waste, used and second-hand products, samples, testing products, bamboo and rattan, and re-treaded tyres except for tyre tread.
The Information System is planned to reopen in June 2026 with voluntary grouping of DDS reference numbers, registration for the new roles, and full API support including for simplified declarations. The Commission will publish contingency arrangements for possible system outages, and will start a close collaboration with Member States to enable relevant data to be pulled from national databases.
Public Repositories to support Due Diligence. The Commission plans to publish repositories of producing-country legislation and certification schemes to support legality checks and risk assessment, which should reduce manual compliance work significantly.
For companies preparing for EUDR, this package is good news. It makes the regulation more workable, especially for downstream actors and businesses trying to determine their role in the chain. It also reinforces that good supply chain mapping, traceability and data management remain essential, which is exactly where TRACT continue to add value.
Please get in touch if you like to hear more about how TRACT can help you get ready for EUDR.
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