Simplification
EUDR Simplification: Regulation (EU) 2025/2650 and the 2026 Commission Review
EUDR simplification: what Regulation (EU) 2025/2650 changed, why the 4 May 2026 review COM(2026) 191 proposed no amendment, and the 2030 general review.
EUDR simplification is two steps: Regulation (EU) 2025/2650, in force since 26 December 2025, changed the obligations of operators and traders, and the Commission's simplification review COM(2026) 191 of 4 May 2026 proposed no further amendment of the basic legal text (Articles 34(1a) and 38 of Regulation (EU) 2023/1115). Which articles changed, and what is still open?
Yes, a review took place: Article 34(1a) of the EU Deforestation Regulation required a simplification review by 30 April 2026, and the Commission published its report on 4 May 2026. It is the EU's current legislation on deforestation.
The rules below cover the changed articles, the review conclusion, the 2030 general review and the French Guiana proposal. The four key figures are listed below.
- Amending act: Regulation (EU) 2025/2650, in force 26 December 2025.
- Review: COM(2026) 191, 4 May 2026, no legislative proposal.
- Commission estimate: about 75 % lower annual compliance costs, EUR 8.1 billion to EUR 2.0 billion.
- Next review: by 30 June 2030, evaluating 12 points.
What Is the EUDR Simplification?
The EUDR simplification is one amending act and one review report: Regulation (EU) 2025/2650, which changed who owes which obligation, and COM(2026) 191 final, the report that Article 34(1a) of Regulation (EU) 2023/1115 required from the Commission.
Regulation (EU) 2024/3234 (in force 26 December 2024) only moved application dates, now superseded. Delegated Regulation (EU) 2026/2102 of 13 July 2026 changed Annex I products. The EUDR was not included in the scope of the environmental omnibus (COM(2026) 191, section 3.1.3), so Regulation (EU) 2025/2650 is not "the omnibus".
What Did Regulation (EU) 2025/2650 Change?
Regulation (EU) 2025/2650 (CELEX 32025R2650, OJ L, 2025/2650, 23.12.2025) was signed on 19 December 2025 and entered into force on 26 December 2025, the third day after publication, under the urgency invoked in its recital 20. It amends Regulation (EU) 2023/1115 "as regards certain obligations of operators and traders" and follows proposal COM(2025) 652 final of 21 October 2025, procedure 2025/0329(COD). The changed provisions are compared below.
| Provision | Before 26 December 2025 | As amended by Regulation (EU) 2025/2650 | Basis |
|---|---|---|---|
| Roles | No downstream operator and no micro or small primary operator category | Four roles: operator, micro or small primary operator, downstream operator, trader | Art. 2(15), 2(15a), 2(15b), 2(17) |
| Condition (c) | Due diligence statement | Due diligence statement or simplified declaration | Art. 3(c) |
| Passing on references | DDS reference numbers passed downstream | Reference numbers or declaration identifiers passed downstream | Art. 4(7) |
| SME downstream operators and traders | Statement rules in Art. 4(8) to (10) | Deleted | Art. 4(8) to (10) |
| Micro or small primary operators | No simplified regime | One-time simplified declaration with Annex III content | Art. 4a; Annex III |
| Downstream operators and traders | Statement duties under the old wording | No DDS; non-SMEs register in the EUDR Information System | Art. 5 |
| Due diligence scope | Due diligence on products "supplied by each particular supplier" | Due diligence "with regard to all relevant products" | Art. 8(1) |
| Annual checks | Check rates on operators | Same rates on operators, non-SME downstream operators and non-SME traders | Art. 16(8) to (10) |
| Fines | Floor of at least 4 % of total annual Union-wide turnover | Same floor; downstream operators named | Art. 25(2)(a) |
| Customs interface | In place by 2028-06-30 | In place by 2029-12-01 | Art. 28(1) |
| Reviews | Assessments due 2024, 2025 and 2028 | Simplification review by 2026-04-30; general review by 2030-06-30 | Art. 34 |
| Application dates | 2025-12-30 (as set by Regulation (EU) 2024/3234) | 2026-12-30; 2027-06-30 for operators that are natural persons or micro or small undertakings established as such by 31 December 2024 (Art. 38(3)); products in the Annex to Regulation (EU) No 995/2010 from 2026-12-30 | Art. 37, 38 |
| Printed products and Annex II | Annex I line ex 49 and Annex II point 4 present | Both deleted | Annex I; Annex II |
New EUDR Roles: Downstream Operator and Micro or Small Primary Operator
Since 26 December 2025 Regulation (EU) 2023/1115 knows four EUDR roles, in this order: operator (Article 2(15)), micro or small primary operator (Article 2(15a)), downstream operator (Article 2(15b)) and trader (Article 2(17)). The tests are on the EUDR roles page.
A downstream operator is "any natural or legal person who, in the course of a commercial activity, places on the market or exports relevant products made using relevant products, all of which are covered by a due diligence statement or by a simplified declaration" (Article 2(15b)). A micro or small primary operator is an operator that is a natural person or a micro or small undertaking, established in a low-risk country, placing relevant products it has itself grown, harvested, obtained or raised (Article 2(15a)).
Downstream Operators and Traders: No Due Diligence Statement
Downstream operators and traders file no due diligence statement (Article 5 of Regulation (EU) 2023/1115, as replaced by Regulation (EU) 2025/2650); they hold the information instead.
Operators pass the reference number of their due diligence statement or the declaration identifier downstream (Article 4(7)). Downstream operators and traders collect supplier and customer data, plus those references only where the supplier is an operator (Article 5(3)), and keep them for five years (Article 5(4)).
Non-SME downstream operators and non-SME traders also register in the EUDR Information System (Article 5(2)) and, on substantiated concerns, verify that due diligence was exercised and that no or only negligible risk was found (Article 5(6)).
A natural person or microenterprise operator may mandate the next downstream operator or trader that is neither to submit the statement for it (Article 6(3)). The duties of downstream operators under the EUDR have their own page.
The Simplified Declaration for Micro or Small Primary Operators
Micro or small primary operators file a one-time simplified declaration with the Annex III content and receive a declaration identifier (Article 4a(2) and (3), inserted by Regulation (EU) 2025/2650). It is not Article 13 simplified due diligence, which keeps the full DDS. Who qualifies is explained for EUDR micro or small primary operators.
Checks, Penalties and Customs After the Amendment
The EUDR penalties floor of Article 25(2)(a) is unchanged: the maximum fine for legal persons must be at least 4 % of total annual Union-wide turnover, and the provision now names downstream operators. National sanctions are set out under EUDR penalties.
Customs receive the DDS reference number or the declaration identifier before release or export, except for an export by a downstream operator (Article 26(4)). The customs electronic interface is due by 1 December 2029, not 30 June 2028 (Article 28(1)).
Annual EUDR checks cover at least 1 % (low risk), 3 % (standard risk) and 9 % of actors plus 9 % of quantity (high risk) of operators, non-SME downstream operators and non-SME traders (Article 16(8) to (10)). The rates are explained under EUDR checks.
Dates, Annex I and EUTR Changes in Regulation (EU) 2025/2650
The amendment replaced the application dates of Article 38: 30 December 2026 (Article 38(2)), and 30 June 2027 for operators that are natural persons or micro or small undertakings established as such by 31 December 2024, with products in the Annex to Regulation (EU) No 995/2010 applying from 30 December 2026 (Article 38(3)). All EUDR dates in force are on the timeline page.
Annex II point 4, the reference to an existing statement under the deleted Article 4(8) and (9) rules, is deleted, and Annex III is inserted. The Annex I line ex 49 (printed products) is deleted with effect from 26 December 2025.
Article 37 repeals the EU Timber Regulation (EUTR), Regulation (EU) No 995/2010, with effect from 30 December 2026, but the EUTR continues until 31 December 2029 for timber produced before 29 June 2023 and placed on the market from 30 December 2026. The transition rules are set out under EU Timber Regulation (EUTR).
What Regulation (EU) 2025/2650 Did Not Change
Regulation (EU) 2025/2650 left five core rules untouched, which are listed below.
- Cut-off date: 31 December 2020 (Article 2(13)), unchanged by Regulations (EU) 2024/3234 and 2025/2650 and Delegated Regulation (EU) 2026/2102.
- Country tiers: Article 29 is not amended, and Implementing Regulation (EU) 2025/1093 (in force 26 May 2025) names 140 low-risk and 4 high-risk countries, every other country being standard; no zero-risk tier exists.
- Geolocation: the Article 2(28) definition is unchanged since 2023.
- Forest: Article 2(4) (more than 0.5 hectares, trees higher than 5 metres, canopy cover more than 10 %) is unchanged.
- Grace period: the six-month enforcement grace period proposed in COM(2025) 652 of 21 October 2025 was never adopted.
What Did the 2026 Simplification Review COM(2026) 191 Conclude?
Yes, a review took place in spring 2026: Article 34(1a) required a simplification review by 30 April 2026, and the Commission published COM(2026) 191 final on 4 May 2026 with the conclusion quoted below.
Article 34(1a) asks for a report "accompanied, where appropriate, by a legislative proposal"; the report attached none. It draws on more than 110 submissions and more than 750 questions received by the end of February 2026.
Annex I Act, Guidance, Repositories and the Information System: What Came With the Review?
COM(2026) 191 announced four accompanying measures. A draft delegated act amending Annex I was published on 4 May 2026 for four weeks of feedback and was followed by Delegated Regulation (EU) 2026/2102 (adopted 13 July 2026, in force 18 September 2026); the lines it added apply from 30 December 2027, as listed under EUDR Annex I.
The report announced an updated Guidance and FAQ; the current documents are Guidance C/2026/3896 (third edition, OJ C, 20 July 2026) and FAQ Version 5 (April 2026), both non-binding (Article 15(5)).
It planned two repositories before December 2026, one of producer-country legislation and one of certification schemes applicable to the relevant commodities; their launch is not established as of 24 October 2026.
The report records that registration in the EUDR Information System opened on 6 November 2024, that the system launched on 4 December 2024 and was temporarily closed, with a reopening planned for June 2026 (section 2.2). Filing is explained under EUDR Information System.
Commission Cost Estimates: About 75 % Lower Compliance Costs
The Commission estimated on 4 May 2026 that annual EUDR compliance costs fall by about 75 %, from EUR 8.1 billion a year under the 2023 text to EUR 2.0 billion a year (COM(2026) 191, section 5.1). The figures are compared below.
| Estimate | Value | Source (COM(2026) 191, 4 May 2026) |
|---|---|---|
| Total annual compliance costs | About EUR 8.1 billion (2023 text) down to EUR 2.0 billion a year, about 75 % lower | Section 5.1 |
| Unit cost per company per year | EUR 1,000 low, EUR 10,000 central, EUR 15,000 high for standard or high-risk sourcing; half for low-risk sourcing | Section 5.1 |
| Low-risk share of importing operators | 51 % (instead of 20 %) assigned half the standard cost | Section 5.1 |
| Micro or small primary operator | EUR 500 per operator per year | Section 5.1 |
| Importing operators | About 352,000 unique operators, reduced to 275,000 after the scope changes | Section 5 |
| Benefits | About EUR 7 billion a year; 208,000 hectares of avoided deforestation and 49 million tonnes of avoided greenhouse gas emissions a year | Section 5 |
Which Stakeholder Requests Did the Review Not Adopt?
The review did not adopt three stakeholder requests: a "zero-risk" country category, "green lanes" for certified products and a de minimis rule (COM(2026) 191, section 3). They are recorded as requests only, and the Commission considers that no threshold volume or value exists below which the Regulation would not apply (FAQ Version 5 (April 2026), 2.3).
What May the 2030 General Review Change?
The Commission must carry out a general review by 30 June 2030 and at least every five years thereafter, and the first report evaluates 12 points, (a) to (l), of Article 34(2); nothing on that list is law until a legislative proposal is adopted. The points are compared below.
| Point | What the Commission evaluates | Earlier deadline (history) |
|---|---|---|
| (a) | Additional trade facilitation tools, in particular for least developed countries and for countries classified as standard or high risk | n/a |
| (b) | Impact on farmers, in particular smallholders, Indigenous Peoples and local communities | n/a |
| (c) | Further extension of the definition of forest degradation | n/a |
| (d) | Threshold for mandatory use of polygons (Article 2(28)) | n/a |
| (e) | Changes in trade patterns that may indicate circumvention | n/a |
| (f) | Whether the checks carried out have been effective | n/a |
| (g) | Possible extension to other wooded land and to the cut-off date (Article 2(13)) | 2024-06-30, deleted |
| (h) | Possible extension to other natural ecosystems, including grasslands, peatlands and wetlands | 2025-06-30, deleted |
| (i) | Further commodities, including maize, and the product list, including biofuels (HS code 3826 00) | 2025-06-30, deleted |
| (j) | Role of financial institutions | 2025-06-30, deleted |
| (k) | Role of downstream operators and traders | New |
| (l) | Role of micro or small primary operators, and the risk of circumvention | New |
Other Wooded Land and Other Natural Ecosystems
Points (g) and (h) ask whether the EUDR should extend to other wooded land and other natural ecosystems such as grasslands, peatlands and wetlands, and whether the cut-off date should change (Article 34(2)). The original Article 34 set impact-assessment deadlines of 30 June 2024 for other wooded land and 30 June 2025 for other ecosystems; Regulation (EU) 2025/2650 deleted both (recital 13).
Maize, Biofuels and Leather: Further Commodities and Products
Point (i) asks whether to add further commodities, including maize, and to amend the product list, including biofuels (HS code 3826 00); neither maize nor HS 3826 00 is in Annex I today (Article 34(2)). Hides, skins and leather of cattle are reserved for the 2030 general review (recital 2 of Delegated Regulation (EU) 2026/2102).
Financial Institutions
Point (j) evaluates the role of financial institutions in preventing financial flows that contribute to deforestation and forest degradation (Article 34(2)). The EUDR places no obligation on financial institutions today.
Downstream Operators, Traders and Micro or Small Primary Operators
Points (k) and (l) review the two regimes created in 2025: the role of downstream operators and traders, and the role of micro or small primary operators, including the risk of circumvention (Article 34(2)).
Is a Further EUDR Amendment Proposed? The French Guiana Proposal
No further amendment or delay is proposed as of 24 October 2026, apart from the French Guiana proposal. Annex I CN codes can still be amended by delegated act (Article 34(1)), subject to a two-month objection period extendable by two months (Article 35(6)).
Commission proposal COM(2026) 661 of 10 September 2026, procedure 2026/0261(CNS), would exclude French Guiana from the territorial scope of the EUDR; it is only proposed, and was at the preparatory phase in Parliament on 24 October 2026. The French Guiana proposal is explained with the rest of the territorial rules.
Every rule on this page is checked against the consolidated text of Regulation (EU) 2023/1115 and COM(2026) 191; see our methodology and fact-checking.
This guide explains the rules; it is not legal advice for an individual case.
How Does the EUDR Simplification Connect to the Timeline, the Delays and the Regulation?
This page covers the obligations and the review, while the timeline and delay pages cover the dates. The sibling pages sit under the EUDR guide.
The amended articles read in context in the consolidated text of Regulation (EU) 2023/1115, with its 39 articles and Annexes I to III.
Did the EUDR Simplification Move the Dates in Force?
Yes, once: Regulation (EU) 2025/2650 set 30 December 2026 and 30 June 2027 (Article 38(2) and (3); for operators that are natural persons or micro or small undertakings established as such by 31 December 2024, with products in the Annex to Regulation (EU) No 995/2010 from 30 December 2026), and COM(2026) 191 changed no date. The schedule is on the EUDR timeline.
Is the EUDR Simplification the Same as the EUDR Delay?
No: the delay is the history of postponements, while the simplification is the content changes and the review. Each postponement and who decided it is on the EUDR delay page.
EUDR Simplification FAQ
Six further questions on the simplification are answered below. More answers are in the EUDR FAQ.
Do SME Operators Still File a Due Diligence Statement?
Yes: SME operators carry full due diligence and file a DDS, except micro or small primary operators, which file the Article 4a simplified declaration. Article 38(3) defers only dates. Rules by company size are under EUDR for SMEs.
Do Imports From Low-Risk Countries Still Need a Due Diligence Statement?
Yes: Article 13 simplified due diligence keeps the Article 9 information, including geolocation, and the DDS (FAQ 1.28). The low-risk country list of Implementing Regulation (EU) 2025/1093 names 140 countries.
Does Certification Replace Due Diligence After the Simplification?
No: certification is complementary information under Article 10(2)(n), and no EUDR certificate exists (FAQ 5.7). What schemes prove is set out under certification and the EUDR.
Does the Simplification Make EUDR Software or Consultants Mandatory?
No: the only mandatory IT is the free EUDR Information System (Implementing Regulation (EU) 2024/3084, Article 18(1)). Consultants and EUDR software are optional.
Does the Grazing Clarification Change the Forest Definition?
No: recital 11 of Regulation (EU) 2025/2650 treats occasional extensive or occasional small-scale grazing in forests as not predominantly agricultural use when it has no detrimental effect on the forest habitat, and Article 2(4) is unchanged. The test is set out under deforestation-free under the EUDR.
Where Can I Read the Amended Text of Regulation (EU) 2023/1115?
The amended text is the consolidated version 02023R1115-20260918 on EUR-Lex. It includes Regulations (EU) 2024/3234 and 2025/2650 and Delegated Regulation (EU) 2026/2102, and the consolidated text is free to read.
Sources
- EUR-Lex: CELEX 02023R1115
- EUR-Lex: CELEX 32023R1115
- EUR-Lex: Regulation (EU) 2025/2650
- EUR-Lex: CELEX 52026DC0191
- EUR-Lex: CELEX 52025PC0652
- EUR-Lex: CELEX 52026PC0661
- EUR-Lex: Delegated Regulation (EU) 2026/2102
- EUR-Lex: Implementing Regulation (EU) 2025/1093
- EUR-Lex: Implementing Regulation (EU) 2024/3084
- EUR-Lex: eur-lex.europa.eu/eli/C/2026/3896/oj/eng
- European Commission, Environment: environment.ec.europa.eu/publications/faq-eudr-implementation_en
- European Parliament: oeil.secure.europarl.europa.eu/oeil/en/procedure-file?reference=2025/0329(COD)