EUDR launch postponed: This will apply in 2026

The amendments from Regulation (EU) 2025/2650 came into force at short notice, before December 30, 2025. The EUDR was originally supposed to take effect on that date. However, the start date was postponed again by one year to December 30, 2026, to give companies additional time for implementation.

In addition, the regulations contain comprehensive simplifications, on the one hand to ensure the competitiveness of EU companies and, on the other hand, to avoid overloading the information system introduced by the EUDR. Simplifications particularly affect companies in the downstream supply chain as well as small and micro primary producers.

We have compiled the most important changes below:

Simplifications for small and micro primary producers in low-risk countries

Small and micro primary producers who produce their products and are based in a low-risk country (see benchmarking) benefit from the following administrative simplifications:

•    No obligation to submit a due diligence declaration: Unlike larger market participants, they are not required to submit a separate due diligence declaration.
•    One-time simplified declaration in the information system: Instead, a one-time simplified declaration is made, which is processed by the information system.
•    Automatic assignment of an identification number and risk assessment: The system automatically assigns small producers an identification number and performs a risk analysis.
•    Simplified localization: Geolocation can be based on the postal address, which reduces the effort required for documentation and tracking of the place of production.

Simplifications along the downstream supply chain

Downstream market participants also benefit from simplifications, although compliance with due diligence obligations must continue to be ensured:

•    Same obligations as retailers: Downstream market participants have the same responsibilities as retailers.
•    No submission of own due diligence declaration: Only the first distributors (e.g., primary producers or importers) must submit a due diligence declaration; downstream market participants are exempt from this requirement.
•    First downstream market participants remain obliged to record their suppliers' reference numbers or identification numbers and information about them.
•    Registration requirement in the information system: Downstream market participants must still register in the information system and provide data.

Change in the goods appendix

Another important adjustment concerns the goods appendix:

•    The previous applicability of the EUDR to the product group “ex 49 Books, newspapers, pictures and other products of the graphic arts, handwritten or typewritten documents and plans” has been deleted. Accordingly, it no longer applies.

Conclusion

The new simplification rules make it much easier to comply with EUDR due diligence obligations, in particular for small primary producers in low-risk countries and downstream market participants. The bureaucratic burden is reduced by eliminating repeated due diligence declarations, automatic identification numbers, and simplified localization. At the same time, supply chain transparency is maintained.

In practice, these adjustments are particularly important for small businesses and SMEs in order to implement compliance requirements efficiently and in a risk-aware manner.