EUDR Keeps 30 December 2026 Date for Large and Medium Operators, With No Further Delay

The EU Deforestation Regulation, usually called the EUDR, requires operators to run a due diligence system and submit a due diligence statement through the EU Information System before covered products enter or leave the EU market. The regulation covers cattle, cocoa, coffee, palm oil, rubber, soya and wood, along with derived products. It has been amended twice, in December 2024 and December 2025, and the application date for large and medium operators is now 30 December 2026.

On 4 May 2026, the European Commission published a simplification package ahead of that date. It covers a review of the regulation’s administrative burden, updated guidance, a draft delegated act on product scope and changes to the Information System. Businesses that import, trade or export commodities such as coffee, palm oil, cattle and wood products now have a fixed timetable to plan against.

Two Application Dates Are Now in Force

The Commission’s regulation page says the EUDR was amended in December 2024 and again in December 2025. Arendt says the December 2025 amendment extended the application date to 30 December 2026. Micro and small enterprises that are covered by the EU Timber Regulation share that date. The page says both amendments introduced simplification measures meant to reduce administrative costs and burdens.

Other micro and small operators have until 30 June 2027. Arendt gives the same two dates and describes the second group as all other micro and small enterprises.

Arendt says placing, making available or exporting products linked to deforestation or forest degradation is prohibited unless three cumulative conditions are met. The products must be deforestation-free, meaning they were not produced on land deforested after 31 December 2020. They must comply with the relevant law of the country of production. And they must be covered by a due diligence statement or simplified declaration.

Application Dates
Large and medium operators must comply from 30 December 2026. Other micro and small operators have until 30 June 2027, according to the Commission’s EUDR page.

What Operators Must Do Under the Due Diligence System

Arendt describes the core duties for operators as three steps. They must collect information, assess the risk that a product is linked to deforestation or forest degradation, and mitigate any risk that is not negligible. The information step includes plot-level geolocation, supplier identity, production date and evidence of legality. After that, they submit a due diligence statement through the EU Information System before any product enters or leaves the market.

Hogan Lovells, summarising the Commission’s package, says the core due diligence obligations remain fully in place. The package provides operational clarifications and a degree of additional flexibility, but the fundamental architecture of the EUDR remains unchanged.

The Commission’s page says operators and traders placing covered commodities on the EU market, or exporting them, must be able to prove the products do not come from recently deforested land or have contributed to forest degradation. The page points to separate guidance documents for implementation.

Arendt lists penalties for non-compliance as fines of up to 4% of annual EU-wide turnover, confiscation of products and revenues, temporary exclusion from public procurement, and public disclosure of infringements.

Lighter Duties for Traders and Small Primary Producers

Downstream operators and traders have lighter obligations under the package, according to Arendt. They must collect and keep information on their direct business partners and keep the identifier of the due diligence statement they received. They must also inform authorities of substantiated concerns. Only non-SMEs must register in the Information System.

Arendt says the May 2026 guidance allows the collect-and-keep duty to be met through information received in standard commercial documents such as invoices, and that downstream actors need not routinely verify the validity of reference numbers. Hogan Lovells says the duty to collect reference numbers is passive. A downstream actor acting in good faith may presume its supplier is not an upstream operator if it receives no reference numbers or declaration identifiers.

Micro and small primary operators, meaning producers who grow, harvest, obtain or raise the products they place on the market in low-risk countries, need only submit a one-time simplified declaration, Arendt says. A larger company may still qualify if the part of its business relating to relevant commodities falls within the EU Accounting Directive size thresholds. Hogan Lovells adds that operators sourcing only from low-risk countries get simplified due diligence under Article 29, unless they have substantiated concerns.

Hogan Lovells says due diligence obligations apply to each legal entity rather than to a group as a whole. Each entity needs its own Information System account, and SME status is assessed per entity. A group may appoint one EU-established authorised representative to submit statements. The FAQs cite CJEU Case C-117/24, dated 13 November 2025, which addressed analogous questions under the EU Timber Regulation and found that a subsidiary referring only to a management system at parent-company level is not sufficient for compliance.

The Commission’s Cost Estimate and What It Has Ruled Out

Hogan Lovells, citing the Commission, says the simplification measures are expected to cut annual compliance costs for affected companies by about 75 percent compared with the original EUDR. The firm attributes the figure to the Commission.

The Commission’s page cites other figures. It describes an initial package of €70 million for the Team Europe Initiative on Deforestation-free Value Chains, aligned with the Global Gateway strategy. It also says the regulation aims to cut carbon emissions linked to EU consumption and production of covered commodities by at least 32 million tonnes per year.

The Commission has ruled out a third extension, so the 30 December 2026 date stands for large and medium operators. Hogan Lovells reports that scope will be adjusted through a draft delegated act, and Generation Impact says the regulation itself has not been reopened. Arendt says the 30 December 2026 date is firmly in place. Hogan Lovells also reports that the Commission says the EUDR is already contributing to structural changes in supply chains, including increased investment in traceability and greater transparency.

The Commission has ruled out a third extension, so the 30 December 2026 date stands for large and medium operators.

A Delegated Act Changes the Product List

The draft delegated act published with the package proposes changes to Annex I. Hogan Lovells lists additions, including soluble instant coffee and certain palm oil derivatives used in oleochemicals and soap. It lists removals, including leather and retreaded tyres, and new exemptions for product samples, packaging, marketing materials, waste, used goods and correspondence. The draft also adds an ex prefix to several Combined Nomenclature entries, so that only products derived from relevant commodities are covered. Hogan Lovells gives coconut oil, bamboo and synthetic rubber as examples of items the change does not capture. Public consultation on the draft ran until 1 June 2026.

Frozen cattle tongues are named as an addition by the Commission’s page and by Generation Impact, but not by Hogan Lovells or Arendt. Generation Impact lists the removals as raw, tanned and finished cattle hides, skins and leather, re-treaded tyres, conveyor and transmission belts, articles of vulcanised rubber, soybeans for sowing, and aircraft and motor vehicle seats. It says the adopted version keeps the draft’s additions but removes more products than the draft did.

The Commission’s page lists Commission Delegated Regulation (EU) 2026/2102 as adding new products, applying from 30 December 2027, and names soluble coffee, certain palm oil derivatives and frozen cattle tongues. Generation Impact says the Commission adopted the act on 13 July 2026, that it updates Annex I without reopening the regulation, and that it must pass scrutiny by the European Parliament and the Council. Hogan Lovells and Arendt describe the May text as a draft. Generation Impact says the adopted act is not yet in force and is provisional until it is published in the Official Journal.

The Information System and Supporting Databases

The Information System is set out in Article 33 of the regulation. The Commission’s page says user registration opened in November 2024 and the system launched on 4 December 2024. Arendt says the system was temporarily closed to integrate the December 2025 changes and was expected to reopen in June 2026.

Hogan Lovells lists planned features, including a simplified declaration format for micro and small primary operators, voluntary grouping of statement reference numbers, registration of new operator roles and a contingency plan. Further improvements are scheduled later in 2026.

Before 30 December 2026, the Commission plans to set up two databases: one on the legislation of producing countries, which supports the legality requirement, and one on certification schemes. The Commission’s page also says the EU observatory on deforestation and forest degradation provides public maps and datasets on forest cover changes.