A Clear Outcome: Full Delay, Simplification, and a 2026 Re-Assessment
1. A Full Delay: All Companies Receive an Additional 12–18 Months
Large and medium-sized companies: now required to comply starting December 30, 2026
Micro and small enterprises: compliance deferred until June 30, 2027
In other words:
All exporters to the EU have gained an extra 12 to 18 months of preparation time.
This is the first major timeline shift since the regulation was adopted—reflecting an attempt to balance regulatory ambition with operational feasibility.
2. Major Simplification: Responsibilities Reallocated, Data Requirements Reduced
The agreement introduces a notable administrative relief across the supply chain.
✔ Only the “first importer” (Operator) must submit the DDS
Downstream traders will keep the DDS number only, without repeated reporting obligations.
This significantly reduces the compliance burden on intermediaries and trading companies.
✔ Micro and small “primary producers” within the EU may file a one-time simplified declaration
Once submitted, the same declaration number can be used long-term.
(This exemption applies only to EU-based small producers and has raised concerns regarding potential WTO non-discrimination issues.)
3. Exemptions Expanded: Books, Newspapers, and Printed Images Removed from Scope
Products considered low-risk for deforestation—such as printed materials—are no longer regulated under EUDR.
4. A Critical New Element: The April 2026 “Big Review”
The European Commission is required to deliver a comprehensive review by April 30, 2026, assessing:
Administrative complexity
Whether further simplification is needed
Whether entirely new legislative proposals should be considered