On 4 May, the European Commission published its simplification review of the EUDR (the EU Deforestation Regulation). The headline reads two ways: the core text of the regulation stays untouched, but a package of technical changes has just landed, and it shifts what’s in scope, what you’ll need to report, and how.
If your business touches cocoa, coffee, soy, palm, rubber, timber or cattle anywhere in the chain, this affects you. Here’s the read.
The context: why this report matters
The EUDR has already been postponed twice. After the second revision adopted in December 2025 (Regulation EU 2025/2650), the application dates landed at:
- 30 December 2026 for large and medium-sized operators.
- 30 June 2027 for micro and small primary operators.
That same revision tasked the Commission with a specific job: deliver a simplification review of the regulation by 30 April 2026, accompanied by a legislative proposal “where appropriate”. That report is now out.
The question that had been doing the rounds among compliance teams for months was straightforward: would they reopen the text? The Commission’s answer is no.
What’s actually changing: the April simplification package
The package has four pieces, and they’re worth looking at separately because each one hits a different type of business.
1. Compliance costs: a 75% drop
The Commission estimates that the measures introduced since 2023 have brought annual compliance costs down from roughly €8.1 billion to €2 billion for in-scope companies. Most of that saving comes from the simplified regime for micro and small operators, plus:
- More countries reclassified as “low-risk”.
- The option to file annual rather than per-shipment declarations.
- Lighter obligations for downstream operators (those who aren’t first to place the product on the EU market).
It’s a number the Commission will lean on to defend that the regulation is workable. And it’s a number your CFO probably wants to see before the next ESG budget conversation.
2. Delegated act on product scope
This is where the most operationally relevant changes sit. The draft delegated act amends Annex I (the list of in-scope products) in two directions:
Products coming in:
- Soluble (instant) coffee.
- Certain palm oil derivatives, including soap made with palm oil.
Products going out:
- Leather: probably the most-discussed change. After months of industry pressure, exclusion is on the table.
- Retreaded tyres.
- Product samples.
- Certain accessory packaging materials.
- Used and second-hand products.
If your supply chain involves any of these, this is the change to track. The delegated act is open to public feedback, so the final list still has room to move.
3. Information system
The IT system (where due diligence statements get filed) has been the technical bottleneck of this whole process. The Commission has confirmed reopening for June 2026, starting with training and production environments, with additional functionalities rolling out through summer ahead of the application date.
Practical translation: if you were waiting to access the system before structuring your data, you’re already six months late.
4. Updated FAQs and guidance
The Commission has already circulated a preliminary FAQ document (which briefly appeared online before being pulled back). The key areas being clarified:
- Obligations of non-SME downstream operators.
- Treatment of re-imports and exports.
- The relationship between EUDR, CSDDD and the Forced Labour Regulation.
- Edge cases for operators importing products manufactured outside the EU using EU-origin raw material.
These look like footnotes. They’re also the kind of footnotes that, in an audit, save or cost you real money.
What’s not changing (and worth flagging)
The country benchmarking system (which sorts jurisdictions into low, standard or high risk) isn’t being reviewed this year. So the low-risk country list published in May 2025 stands as the reference.
The application dates aren’t moving either: 30 December 2026 and 30 June 2027. If anyone in your organisation was betting on a third postponement, today’s a good day for them to lose that bet.
The due diligence core (geolocation data collection, risk assessment, mitigation measures) is also untouched. It is what it was.
What you should be doing now
Less than 8 months until application. The sensible move at this stage:
- Re-check your scope. If you’re working with leather, soluble coffee or palm derivatives, recalculate what’s in and out following the delegated act.
- Map suppliers with geolocation. Without GPS coordinates of plots (or postal addresses for micro-operators in low-risk countries), there’s no valid due diligence statement. Tools like supplier engagement help structure this from the start.
- Define your role in the chain: primary operator, downstream operator, trader? Obligations differ significantly, and many companies still haven’t pinned this down.
- Start testing the IT system as soon as it reopens in June. Don’t wait until October.
The Dcycle angle
EUDR isn’t a standalone project. If you’re already working on CSRD, CSDDD or the Forced Labour Regulation, most of the information you need (suppliers, geolocation, due diligence, evidence) is the same. The output format is what changes.
At Dcycle, we help companies structure data once and report to multiple frameworks without duplicating effort. If you want to see how that works specifically for EUDR, book a demo.