EUDR Simplification Review & Guidance for 2026

1. The December 2025 Amendments and the Simplification Review

Last year, after EU Commissioner Jessika Roswall flagged issues with the EUDR’s main compliance portal, the TRAde Control and Expert System (TRACES), the European Commission forwarded the issue to Parliament. During deliberations, EU Parliamentarians had the opportunities to introduce further amendments to the scope of the EUDR. The main changes accepted by the European Parliament were:

• One-year-delay:The Regulation was delayed by a year for all organizations. Large organizations are now only required to comply with EUDR requirements starting on the 31st of December 2026, Small and Medium organizations are required to comply from 31st of June 2027;
• Focus on first placers: Companies making relevant products on the market are now no longer required to conduct full-due diligence on their supply chains, that responsibility is limited to importers who first place products on the EU market.
• Simplified Declarations for Micro and Small primary operators: Micro and small primary operators, who produce relevant products in low-risk countries are now only required to produce and submit a one-time simplified declaration to the EU's TRACES portal.

Alongside these changes, Parliament also tasked the Commission with conducting a simplification review of the regulation identifying other points where the EUDR could be further simplified. This simplification review forms the main content of this article.

3. Draft Delegated Regulation Amending Annex I of the EUDR

Along with the documents providing additional guidance for EUDR compliance, the EU Commission also published a draft delegated act amending the relevant products list under the EUDR’s Annex I. Importantly, while this draft delegated act does not need to be accepted by parliament, it is still subject to a 4 week public consultation period, and items included, or excluded from the regulation’s scope may be revised. As such, this list is not yet final. That said, key changes so far include:

• Extra clarifications regarding species included under cattle, Oil palm, rubber and wood. The amendment makes the exclusion of animals such as buffaloes, and bison from the regulation’s scope formal. Other excluded items include:
  • Items derived from Babassu oil;
  • Balata, gutta-percha, guayule, chicle and synthetic rubber;
  • Bamboo, rattan, and other materials of a woody nature
• Exclusion of leather goods, as well as hides and skins of cattle;
• Inclusion of several categories of oil palm-based products, particularly relating to cosmetics manufacturing, and soaps;
• Exemptions for second-hand products, or products classified as waste as defined under Directive 2008/98/EC.

4. EUDR Guidance Document (version 3)

The third version of the EUDR Guidance Document offers further guidance for entities in-scope of the regulation and deliberates on some crucial points introduced in the December 2025 amendments, improving clarity, including on application timelines, precision of the provisions for operators and traders, facilitating simple and efficient due diligence and traceability. Importantly, much like the FAQs discussed in the next section, the Guidance Document does not possess a legal mandate. These documents are purely informative and are meant to simplify compliance for in-scope entities. They do not supplant the legal requirements stated in the Regulation itself. Key differences between this, and previous versions of the guidance documents include:

1. Downstream verification is now reactive: In line with the December 2025 amendments' ambitions of simplifying compliance for downstream actors, downstream operators and non-SME traders no longer need to ascertain upstream due diligence or submit their own DDS. Verification that due diligence was properly conducted is only required in response to substantiated concerns about potential non-compliance.
2. Legality evidence collection is now proportionate to risk: Rather than treating documentation requirements uniformly across all supply chains, operators should now prioritize in-depth evidence collection where initial information indicates higher risk of non-compliance. For lower-risk supply chains, operators are explicitly not required to systematically collect comprehensive legal documentation for each plot of land or to obtain specific document types such as individual land titles.
3. Geolocation alone can satisfy the deforestation-free evidence requirement for low-risk sourcing: For operators benefitting from simplified due diligence under Article 13, the requirement to provide "adequately conclusive and verifiable information" that products are deforestation-free can now be fulfilled simply by collecting geolocation coordinates (or postal addresses for MSPOs), without additional independent verification of the information's substance.
4. The scope of "relevant legislation" for legality assessments has been narrowed: Legislation of the country of production is now only relevant for the Article 3(b) legality requirement if it is "directly linked" to halting deforestation and forest degradation, rather than merely capable of being "linked" to those objectives. This narrows the range of laws operators must identify and assess as part of their due diligence.

5. EUDR FAQs Version 5.

The 5th iteration of the EUDR FAQs were originally published in the EU’s document repository on Wednesday 29th of April. That said, the document was summarily removed from the portal and re-published alongside the Simplification Review on Monday, the 4th of May.  The main changes to the document were made to reflect the changes brought about by the December 2025 amendments. Several changes are also meant to reduce compliance burdens for companies in-scope of the regulation:

1. Operators are allowed to submit DDS before harvest: When sourcing from stable, unchanged plots, operators can submit DDSs before commodities are harvested.
2. Re-importers are treated as upstream operators: Companies re-importing products that had previously been placed in the EU’s market must now prove that products had already been in the EU before to qualify for lighter treatment as downstream operators.
3. Downstream Operators are not required to have a DDS number at customs when exporting: Downstream operators are no longer required to present DDS numbers at customs before exporting relevant products, they can now rely on TARIC certificate codes to prove compliance.
4. Purely domestic chains: For operators placing EU-produced products on the market, the DDS submission deadline is now tied to the start of the delivery process (e.g., loading cargo), rather than being due at the point of concluding a supply agreement.
5. Plot of land declarations are more flexible: operators can declare an entire homogeneous property rather than only the specific cultivated sub-area, reducing geolocation granularity requirements.
6. E-commerce companies get explicit guidance: The FAQs explicitly address E-Commerce companies, even those not explicitly located in the European Union, adding that, whether serving customers in a B2C or B2B setting, E-commerce companies are responsible for the compliance of their products.