The European Union Deforestation Regulation (EUDR) entered into force on 29 June 2023, but its obligations only start to apply on 30 December 2026. Since its adoption, the EUDR has been postponed twice and changed in several ways:

• The obligations were simplified.

• A new "downstream operator" role was introduced.

• The list of products in scope was adjusted.

For companies that prepared based on the original text, some of that work now needs updating. This article sets out the timeline, what has changed and the practical steps to take before the regulation applies. For a full explanation of the roles and due diligence requirements, read our article What is the EUDR and what does it mean for companies?

The EUDR timeline

The Commission's 2026 simplification review did not reopen the regulation, so no further changes to the dates are planned before it applies.

What has changed since the original regulation?

1. A new role: the downstream operator

Regulation 2025/2650 introduced the downstream operator. This is a company that places on the market or exports products made from relevant products already covered by a due diligence statement (DDS), such as a processor turning cocoa into chocolate.

Downstream operators and traders don't submit their own DDS. Their obligations are lighter:

• All downstream operators and traders keep supplier and customer details for at least five years.

• The first downstream operator or trader after the operator also collects the DDS reference numbers from its suppliers.

• Non-SME downstream operators and traders also register in TRACES.

2. A simplified declaration for micro and small primary operators

Some micro and small primary operators can submit a one-time simplified declaration instead of a DDS for each placement. This applies to operators that place their own produce on the market and are based in a low-risk country. They may also give a postal address instead of geolocation data.

3. Changes to the product scope

The EUDR still covers seven commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood. Delegated Regulation 2026/2102 changed which derived products are included.

Added (applies from 30 December 2027):

• Soluble coffee

• Palm oil oleochemical derivatives

• Frozen cattle tongues

Removed:

• Cattle hides, skins and leather

• Conveyor belts and other vulcanised rubber articles

• Soya for sowing

• Aircraft and vehicle seats

Printed products had already been removed by Regulation 2025/2650.

Please note: for some products the scope was narrowed rather than removed. For example, retreaded and used tyres are now only in scope as new tyre treads.

What hasn't changed

• Products must still be deforestation-free, meaning no deforestation after 31 December 2020.

• They must be legally produced under the relevant laws of the country of production.

• They must be covered by a DDS or a simplified declaration before they are placed on the EU market or exported.

• The penalties stay the same. Maximum fines must be at least 4% of a company's EU-wide annual turnover.

Practical steps to prepare

Step 1: Check which of your products are in scope

Compare your product codes with Annex I of the EUDR, including the changes made by Delegated Regulation 2026/2102. Remember that the newly added products only apply from 30 December 2027.

Step 2: Determine your role for each product

Your role can differ per product and per supply chain:

• Operator: you are the first to place the product on the EU market, or you export it.

• Downstream operator: you place on the market or export products made from products already covered by a DDS.

• Trader: you make products available that are already on the EU market.

Also check whether you buy directly from an operator. If you do, you are the first downstream operator or trader, and you have extra obligations.

Step 3: Act on the obligations for your role

If you are an operator:

• Collect product information, including the geolocation of every production plot.

• Assess the risk of non-compliance, and take steps to reduce it if the risk is more than negligible. Products from low-risk countries qualify for simplified due diligence.

• Submit your DDS in TRACES before placing products on the market or exporting them.

• Keep each DDS for five years, and share the DDS reference numbers with your customers.

• Review your due diligence system at least once a year.

If you are a first downstream operator or trader:

• Identify which of your suppliers are operators.

• Collect the DDS reference numbers or declaration identifiers for every in-scope product you buy, and link them to the right product.

• Keep these records, together with your supplier and customer details, for at least five years.

If you are further down the chain:

• Keep the name, address, email address and website of your suppliers and customers for at least five years.

Applies to all downstream operators and traders:

• Provide your records to authorities on request.

• Report any concerns about non-compliance to the authorities and to your customers.

• If you are not an SME, register in TRACES, and verify that due diligence was carried out whenever you receive substantiated concerns.

Step 4: Check the country risk classification

The European Commission classifies countries as low, standard or high risk. Belarus, Myanmar, North Korea and Russia are currently classified as high risk.

The classification affects two things:

• Whether operators can apply simplified due diligence.

• How often authorities check companies. The minimum annual check rates are at least 9% of relevant companies for high-risk countries (and 9% of product quantities), 3% for standard-risk countries and 1% for low-risk countries.

Step 5: Set up your processes and systems now

Check whether your current systems, often an ERP, can reliably store, link and retrieve the information your role requires. Make sure you can produce records quickly when an authority or customer asks for them. Agree with your suppliers how and when they will share DDS reference numbers.

How Simvia supports first downstream operators

For First Downstream Operators, the biggest practical challenge is collecting DDS reference numbers from suppliers and keeping them linked to the right products. Simvia gives you one place to:

• Tag the products and suppliers that fall under the EUDR.

• Map the supply chain of each product.

• Request DDS information from suppliers based on rules you set.

• Receive DDS documents and reference numbers in a simple way from suppliers. Simvia extracts the key details from shared documents using AI.

• Keep audit-ready records for five years or more, with an Excel export so you can respond quickly to authorities and retailers.

Want to know how Simvia can help you prepare for 30 December 2026?