The measures include a new delegated act on scope, updated FAQs, and an updated guidance document.
By Michael D. Green and James Bee
Key Points:
- The Commission has unveiled a package of EUDR measures aimed at providing guidance and easing implementation.
- The delegated act will adjust the range of commodities and products falling within the EUDR’s scope.
- The Commission has confirmed that it will not reopen the text of the EUDR, so companies should continue preparing for the 30 December 2026 application date (or 30 June 2027 for micro and small operators).
On 4 May 2026, the European Commission (Commission) presented a package of measures on the EU Deforestation Regulation (EUDR), as mandated in December 2025 as part of the agreement to delay and further simplify the EUDR.
The measures include: (1) a simplification review report; (2) updated FAQs and an updated guidance document; (3) a draft delegated act on the product scope (published for a four-week public feedback period); and (4) updates to the Information System by way of a draft implementing act.
In this blog post, we set out the background and status of the EUDR, and summarise elements of the measures.
Background to the EUDR and Simplification Measures
The EUDR requires operators placing covered commodities or products on the EU market, or exporting them from the EU, to conduct due diligence to demonstrate that the goods are “deforestation‑free” and produced in line with the laws of the country of production. The EUDR covers cattle, cocoa, coffee, palm oil, rubber, soy, and wood, in addition to a wide range of products derived from those commodities, and is intended to capture the commodities linked to a large proportion of agricultural-driven deforestation.
The EUDR entered into force on 29 June 2023 and was originally intended to apply from 30 December 2024, but the application date has been postponed twice. In December 2024, the European Parliament and the Council delayed the application date by one year to 30 December 2025 to allow operators additional time to prepare.
In December 2025, a further amendment postponed the application date by another year to 30 December 2026 for most large operators and traders (with a date of 30 June 2027 for micro and small operators), and introduced substantive changes intended to simplify practical implementation and reduce the volume of data submissions required. Earlier that year, in May 2025, the Commission introduced the Benchmarking Implementing Regulation, which classifies countries of sourcing into risk categories (high, standard, or low); low-risk countries benefit from simplified due diligence, allowing enforcement measures to be focussed on higher-risk areas.
Simplification Review Report
The simplification review report assesses the impact of the simplification measures introduced since the EUDR entered into force, with particular attention to micro and small operators such as farmers and foresters. It concludes that the measures already introduced, together with the new measures accompanying the review report, will deliver a substantial reduction in administrative burden and considerable simplification for in-scope companies, particularly operators sourcing from low-risk countries, micro and small primary operators, and downstream actors. Taken together, the Commission estimates that the simplification measures will reduce annual compliance costs for companies subject to EUDR obligations by 75%.
Updated FAQs
The fifth iteration of the FAQs follows the same 10-chapter structure as the April 2025 iteration, covering: (1) Traceability; (2) Scope; (3) Subjects of Obligations; (4) Definitions; (5) Due Diligence; (6) Benchmarking and Partnerships; (7) Digital Implementation (the EUDR Information System); (8) Timelines; (9) Other Questions; and (10) Penalties. Updates and additions relative to the April 2025 iteration are flagged as (UPDATED) or (NEW). The FAQ document is intended to provide information and is not legally binding.
Updated FAQs in Chapter 2 provide further clarity on which products, activities, and situations fall within the EUDR’s remit. Key updates include revised guidance on the treatment of wood and paper used for packaging, recycled paper and paperboard, tyres, and products listed in Annex I that do not themselves contain listed commodities (such as bamboo).
New FAQs in Chapters 3 and 5 clarify, among other things, that the obligation of first downstream operators to collect reference numbers from upstream operators is passive (with no duty to proactively investigate the veracity of such information). The new FAQs also clarify: (1) the treatment of re-imports as a downstream activity with use of a conventional reference number at customs; (2) dual roles within a single supply chain; (3) the use of EUDR due diligence systems for other EU due diligence-related laws, subject to those instruments’ additional requirements; and (4) the applicability of the EUDR to online and distance sales, with EU consumers purchasing for private use confirmed as not being operators.
See the updated FAQs.
Updated Guidance Document
The third edition of the guidance document is intended to be used as reference material to clarify parts of the legislative text for operators, traders, national competent authorities, enforcement bodies, and national courts. It does not replace, add to, or amend the provisions of the EUDR and should not be considered in isolation. The document is intended to be read in conjunction with the FAQs, which provide additional examples and clarifications.
The updated edition of the guidance document is intended to clarify aspects including application timelines and precision of the provisions for operators and traders.
See the updated guidance document.
Delegated Act on Scope of Application
The Commission has published a draft delegated act amending the list of in-scope products in Annex I of the EUDR. The draft notes that the Commission intends to introduce “limited and targeted technical fixes” to provide certainty on the products that fall within scope of the EUDR. The draft delegated act is open for a four-week public feedback period, until 1 June 2026.
Proposed additions include soluble (instant) coffee, certain palm oil derivatives (including soap made with palm oil), and frozen cattle tongues, with a view to preventing gaps and the relocation of deforestation risk. Proposed removals include retreaded rubber tyres and cattle hides, skins, and leather.
The draft delegated act also introduces a number of horizontal exemptions and clarifications, including for samples and products used for examination, analysis, and testing; single-use and reusable packaging materials and containers; marketing and information materials; waste, used, and secondhand products; and items of correspondence.
Information System
In parallel, the Commission is updating the EUDR Information System, which is a registry of due diligence statements that allows operators, traders, and their representatives to submit electronic due diligence statements to the relevant authorities. The Commission previously proposed targeted amendments in October 2025 to reduce the strain on the system and ease the administrative burden.
Following a temporary closure, the Commission plans to relaunch the Information System in June 2026, with further functionality rolled out over the summer and ahead of the EUDR’s date of application. The Information System will include new features intended to bring operational simplifications.
Next Steps
The Commission has confirmed that it will not reopen the text of the EUDR and will instead focus on simplification actions, adjusting the scope through the delegated act rather than a further legislative process. With the core obligations of the EUDR unchanged, companies should prepare for the current application dates and review the updated FAQs and guidance document for clarifications on their specific obligations.
This blog post was prepared with the assistance of Samantha Banfield and James Thompson at Latham & Watkins.
Latham & Watkins will continue to monitor developments relating to the European sustainability regulatory landscape.
