EUDR: what the simplification review means for businesses

Which products fall under the EUDR?

The EUDR impacts businesses across many industries around the world. Products made from key commodities and sold in the EU are subject to strict new requirements. These include timber, rubber, coffee, cocoa, soy, palm oil and cattle.

The regulation affects businesses in all parts of the supply chain, from farmers and foresters, to manufactures, exporters and traders. Products covered by the regulation include paper, furniture, beauty products, processed food, construction materials, car tyres, food ingredients, and packaging. 

This list is by no means exhaustive. Our Responsible Sourcing experts can help if you're not sure whether the EUDR will affect your business.

Recent changes to the EUDR

Senior Responsible Sourcing Manager, Maggie Fitzherbert, has pulled together the key outcomes of the simplification review in this article. You can also watch our recent webinar.

Key dates

• July 2026: re-launch of the TRACES NT system

• end of 2026: 2 new tools will be launched to help businesses carry out due diligence

• January 2027: EUDR enforcement starts for medium and large companies

• July 2027: EUDR enforcement starts for micro and small companies

• January 2027 to January 2030: transition period for the EU Timber Regulation

Changes to Products Covered by EUDR

Some products have been removed from the regulation, while others have been added. Please note that “ex” means only products containing the relevant commodity are in scope.

Removed

• re-treaded tyres (ex 4012)

• conveyer or transmission belts or belting of vulcanised rubber (ex 4010) ​

• other articles of vulcanised rubber other than hard rubber, not elsewhere specified in chapter 40 (ex 4016) ​

• leather and hide products (ex 4101, ex 4104, ex 4107) ​

• seats, whether or not convertible into beds, and parts thereof, of wood (ex 9401)

• soya beans have been replaced by a more targeted HS code ‘1201 90 00’

Added

• rubber tyre treads (ex 4012 90 30) ​

• frozen cattle tongues (ex 0206 21 00)

• coffee extracts, essences and concentrates (ex 2101 11 00) 

• 14 product codes for oil palm derivatives (except where these are used in the manufacturing of medicinal products for human or veterinary use) ​

• 2 soap product codes as oil palm derivatives (ex 3401 11 and ex 3401 20) ​

• 6 product codes for seats most likely to contain wood

New support tools

Companies classed as Operators must prove their products were made legally.

This can be difficult because businesses must comply with many types of laws, including:

• harvesting and land-use permissions

• tax laws

• health and safety regulations

• environmental protection rules

• workers' rights and labour laws

To help businesses, two online databases will be available by the end of 2026:

• a database of relevant laws in producing countries

• a database of approved certification and verification schemes

These tools should make compliance easier and more consistent.

Changes to TRACES NT

TRACES NT is the online platform used to submit EUDR Due Diligence Statements. The platform has recently undergone updates and improvements. After being offline for several months, it re-opened in July. Recent improvements include:

New features include:

• tools for Competent Authorities to analyse geolocation data more effectively

• the ability to submit simplified Due Diligence Statements where applicable

• new user roles, including Micro and Small Primary Operators (MSPOs)

• updated technical specifications, including new features and contingency plans for outages

• voluntary grouping features

• stronger confidentiality security measures

The aim is to make the system easier, safer, and more efficient to use.

New company categories

There are now four main company types under EUDR.

'First placers' are companies placing relevant products on the market for the first time, who will be categorised as either:

• Upstream Operators

• Micro and Small Primary Operators (MSPOs)

Those 'making available' on the market are the EU companies downstream from the first placers will be categorised as either:

• First Downstream Operator / Trader

• Subsequent Downstream Operator / Trader

Exporting

Any of these company types can export products. The requirements depend on the company's classification.

Re-importing

Companies are considered downstream as long as they can prove that the product was previously placed in the EU market, for example by retaining customs and shipping documents.

If the re-importer cannot provide evidence that the product has been the EU market previously, they will be treated as an Upstream Operator.

What makes an MSPO?

A business qualifies as a Micro and Small Primary Operator (MSPO) if it meets all the following criteria:

1. it places the product on the market for the first time

2. it sells products it has produced itself

3. it operates in a country classified as low risk under EUDR

4. it meets the definition of a micro or small business

What are the reduced requirements?

MSPOs benefit from simpler rules:

• they can submit a one-off simplified declaration instead of regular Due Diligence Statements

• they can use a postal address or similar location information instead of detailed geolocation data

Downstream companies

Requirements for Downstream companies have been significantly reduced over time, for example, they do not need to:

• carry out due diligence

• check that upstream companies are compliant

• submit statements

Instead:

• first downstream companies must be registered on TRACES and collect the reference numbers from suppliers

• subsequent downstream companies only need to keep information of their suppliers and buyers

Summary

The 2026 EUDR simplification review makes compliance much easier for many businesses. Key changes include:

• fewer products covered by the regulation

• new support tools and databases

• simpler processes in the TRACES NT system

• new company classifications

• reduced obligations for small producers and downstream businesses

Overall, the changes are intended to reduce costs, simplify compliance, and make the rules easier to follow. More information on requirements for different types of companies, including MSPOs and Downstream Operators / Traders, can be found in the FAQ on EUDR Implementation, Section 3, Subjects of Obligations.