EUDR Update: What the Revised Rules Mean for Your Role in the Supply Chain
The Parliament, Council and Commission have struck a political deal on the EU Regulation on Deforestation-free Products, reshaping who does what in the supply chain and easing the load for many downstream players. So, what does this mean for you?
What rules apply to first operators?
There are no changes to your due diligence obligations. You must still ensure that all commodities or products you place on the market are legally produced and deforestation free as of 2020, and you must submit due diligence statement (DDS).
What rules apply to downstream operators or traders?
There are changes to your obligations. You no longer have to submit due diligence statements (DDS) and you will only have to collect and keep DDS reference numbers if you are buying directly from a first operator. If you are buying from another downstream operator or trader, there is no longer a need to collect DDS. You also no longer have to pass on DDS reference numbers to your buyers.
What rules apply to sourcing from low-risk countries?
Small and micro (SME) first operators from low-risk countries will only submit a one-time simplified declaration, receive a declaration identifier, and can use a postal address instead of geolocation for the production plot. Updates of major changes are only voluntary.
Larger organizations that meet 2 of the 3 SME definition thresholds for their EUDR relevant activities in a financial year can also rely on the simplified route of SME first operators.
What products are out of scope?
Certain printed products such as books, newspapers, printed pictures are removed from scope.
When do you need to be ready?
Medium & large companies: full compliance by 30 December 2026 – a few extra months to get systems, contracts and data flows in order.
Small and micro companies: new deadline 30 June 2027, giving smaller players an extra six months to catch up.
What happens next?
Formal Approval: This is a provisional political agreement and both the Parliament and Council still have to formally approve the final text. Please look out for more news in the coming 2 weeks.
Additional review and guidance: the Commission must review the EUDR’s impact (especially on smaller operators) and propose guidelines, IT improvements and, if needed, legislative tweaks by April 30, 2026.
How can TRACT help?
Use the extra time wisely. With TRACT, you can onboard your suppliers and begin collecting data now. Preparing for EUDR is not an overnight process and starting now means less time spent scrambling a few months from now. TRACT can help you assess your supply chains for deforestation, coordinate with suppliers to mitigate risks, and prepare to submit due diligence statements so you are ready by the new deadlines.
To learn more about how TRACT can help you get ahead, reach out to our sales team at: sales@tract.eco or drop us a message using the form below.
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