EUDR: what will change in 2026, and what will stay the same?

The EU Deforestation Regulation (EUDR) is no longer just some distant regulation that doesn’t affect us. In early May, the review of the simplification measures, the fifth edition of the FAQ, and an updated guidance document were published. This definitively shifts the discussion from “what does this mean?” to “how do we organize this?” In this article, we’ll explain the changes and how your organization can prepare for them.

Table of contents

Less administrative burden, same responsibilities

The European Commission’s message is consistent and clear: the EUDR will not be reopened for substantive changes or watering down, but will be implemented step by step. Thus, the EUDR is no longer optional — the focus is shifting to implementation. Based on feedback from the market, the decision was made to clarify and simplify the regulation, with the goal of creating workable processes and reducing administrative burdens, without compromising companies’ responsibilities.

Nothing has changed regarding the timelines; these are the key dates for the EUDR:

These dates are fast approaching. For organizations subject to the first deadline, this means that, in practice, 2026 is already the year of implementation. Getting due diligence processes, data flows, and collaboration with suppliers in order requires significant preparation. Starting early is therefore essential to ensure compliance and avoid operational surprises.

Recap: what is the EUDR?

The EU Deforestation Regulation (EUDR) is European legislation aimed at reducing Europe’s contribution to global deforestation and forest degradation, as well as the associated CO₂ emissions and loss of biodiversity. The law requires companies throughout the supply chain — from importers and producers to traders and (in some cases) downstream parties — to actively demonstrate that their products do not contribute to deforestation. The regulation applies to seven raw materials — cattle, cocoa, coffee, palm oil, rubber, soy, and wood — and a selection of derived products, such as tires and furniture.

Specifically, companies that place these products on the EU market or export them as “operators,” and “traders” who deal in these products, must demonstrate that the products:

These obligations are ensured through a due diligence process, for which operators are primarily responsible for carrying out and documenting. For each shipment, these operators must submit a Due Diligence Statement (DDS) via the European Commission’s IT system (TRACES), thereby formally declaring that all EUDR requirements have been met. Starting in June, the system will be made available so that companies can submit, update, and test Due Diligence Statements and simplified declarations in preparation for the EUDR’s entry into force.

Developments within the EUDR: What has been clarified or amended since december 2025?

All scope changes are included in the Draft Delegated Act on Product Scope. 👉 Link: Draft Delegated Act on Product Scope

For further clarification on these changes, the fifth edition of the EUDR FAQs is available. It answers frequently asked questions from real-world practice, including those regarding the division of roles in the supply chain, the application of simplifications, handling substantiated concerns, and the setup of IT systems such as TRACES.

👉 Link: FAQ

What stays the same?

Despite the recent clarifications, the core obligations of the EUDR remain unchanged:

What does this mean, specifically, for your organization?

Now that the main provisions of the EUDR have been finalized and the European Commission is only publishing limited, operational guidance, now is the time to take action. EUDR compliance takes time: it requires redesigning processes, establishing long-term partnerships with suppliers (often outside the EU), reaching agreements on data exchange, and structurally embedding due diligence into daily operations. Those who start later increase the risk of disruptions in the supply chain or non-compliance when the regulation takes effect. Organizations can start now by taking the following concrete steps:

1. Reassess your product scope and HS classifications. Carefully identify which products and raw materials fall under the EUDR and verify that the HS codes used are correct. Errors in scope determination will affect all your subsequent steps.

2. Determine your role and position in the supply chain. Determine whether you operate as an operator, a trader, or both, and at which point(s) in the supply chain you are responsible for due diligence. This determines which obligations you have and what information you must receive or pass on.

3. Start discussions with suppliers about data and responsibilities. Begin discussions with suppliers well in advance regarding:

This is often the most time-consuming step and cannot be arranged at the last minute.

4. Evaluate your current due diligence processes. Assess whether your existing due diligence is not only EUDR-compliant, but also:

In doing so, explicitly consider how EUDR requirements can be integrated into broader supply chain transparency and ESG processes, rather than treated as a standalone compliance project.

Our Vision: EUDR as the Foundation for Future-Proof Supply Chain Transparency

The EUDR does not stand alone. The requirements regarding traceability, data quality, and due diligence serve as an important starting point for gaining deeper insight into the supply chain and structurally embedding due diligence processes within the organization. These foundations align closely with other European developments, such as the CSRD, CSDDD, and the Forced Labor Regulation.

Organizations that carefully design their EUDR processes now are laying the foundation for a single, coherent approach to supply chain transparency, governance, and risk management. By treating the EUDR as a starting point for a structured and repeatable due diligence approach, they avoid the need for multiple, disparate systems required by different regulations down the line and prevent the fragmentation of data, responsibilities, and decision-making.

In this way, EUDR is shifting from a purely legal obligation to a strategic investment in a robust, future-proof approach to supply chain transparency — an approach that helps organizations gain control over their value chains, better manage risks, and scale up sustainably.

With experience in EU sustainability legislation, supply chain analysis, and due diligence implementation, Lydia and Nikki help organizations establish a practical and future-proof EUDR compliance framework — from interpretation to implementation.