EUDR Deadline Set With Fewer Downstream Duties
- EUDR applies in full from 30 December 2026, with small companies given until mid 2027.
- Downstream operators no longer issue their own due diligence statement but must keep supplier data for five years.
- Producer countries are now rated low, normal or high risk, with no "no risk" category adopted.
Due diligence responsibility now falls on whoever first places goods on the EU market, not on whoever buys last.
From 30 December 2026, the EU Deforestation Regulation applies in full to wood, coffee, cocoa, palm oil, soya, rubber and cattle, along with products made from them such as roast coffee, chocolate, tyres, gaskets, leather goods, soya oil, paper and furniture. Buyers of these goods now have a clearer, and in several respects lighter, set of obligations than the original rule set out.
The regulation has already been pushed back twice, from 2024 to 2025 and then to 2026, trade title Beschaffung aktuell reports. Small companies have until mid 2027. The delays followed pressure from affected businesses and trade bodies, who argued the original rules carried too much paperwork and too little judgement about actual risk. The EU responded with amendments in December 2025 and two further legal acts spelling out how the regulation is to be carried out.
The biggest practical change is a new category called the downstream operator, meaning any business that processes or passes on a product already placed on the market by an importer. According to Annerose Lichtenstein of the BLE, Germany's Federal Office for Agriculture and Food, a downstream operator no longer has to issue its own due diligence statement or check that the upstream statement was done properly. Instead it must collect and keep certain supplier and customer details, including the reference number, for five years. Lichtenstein says the upstream supplier is obliged to actively offer this data to the downstream party, while the downstream buyer does not have to chase it. Responsibility sits with whichever company is first to place the product on the EU market; the buyer further down the chain only has to store what it is given, ready to produce it if checked.
Theresa Schwämmlein, principal consultant at Inverto, says the December 2025 changes make it more important than ever to know exactly where a company sits in each supply chain it buys through, since that position now determines which obligations apply. She points to the need for clear communication with other parties in the chain so each side's role is correctly identified.
Producer countries are now classed as low, normal or high risk, the first time the regulation has graded them this explicitly. Germany had pushed for a fourth category of "no risk", intended to cover all EU member states, but this was not adopted. A low risk rating does not remove the need for an EUDR check, only how intensive that check needs to be. Micro and small businesses in low risk countries that produce raw materials themselves also get a lighter route in: a single simplified declaration in the EUDR information system, rather than a full due diligence statement each time.
Lichtenstein says enquiries to the BLE have shifted. Geolocation data was seen as the hardest part under the original rules; now the questions are mostly about identifying and correctly assessing the relevant legal requirements in producer countries.