On 13 July 2026, the European Commission adopted a further set of measures aimed at implementing Regulation (EU) 2023/1115 of the European Parliament and of the Council on the making available on the Union market and the export from the Union of certain commodities and products associated with deforestation and forest degradation (hereinafter the “EUDR”).
General Information
The adopted acts represent the completion of the simplification package presented by the Commission in May of this year, the objective of which is to eliminate uncertainties of interpretation, reduce the administrative burden and facilitate companies’ preparations for the time when the EUDR becomes applicable.
Although the basic obligations of operators remain unchanged, the newly adopted delegated and implementing rules introduce a number of adjustments of practical significance. In addition to changes to the scope of products subject to the EUDR, amendments have also been made to the information system for submitting due diligence statements, and the Commission has simultaneously published updated guidance and answers to frequently asked questions (FAQs), which are intended to harmonise the interpretation of the Regulation across the Member States.
The Date of Application of the EUDR Remains Unchanged
The adopted measures do not in any way change the timeline for the application of the Regulation itself.
The EUDR will begin to apply from 30 December 2026 for most operators and traders, while, in most cases, it will apply to micro and small enterprises from 30 June 2027.
The Commission has once again emphasised that its objective is not to change the fundamental concept of the Regulation, but to ensure its predictable and uniform application throughout the European Union.
The Delegated Regulation Clarifies the Scope of Products
The most significant change is the adoption of a delegated regulation[1] amending Annex I to the EUDR, which contains the list of products subject to the regime of the Regulation.
In carrying out the review, the Commission relied on practical experience gained during preparations for implementation, as well as on comments from the business sector.
The objective was to remove products whose inclusion did not correspond to the purpose of the regulation or resulted in a disproportionate administrative burden, and, conversely, to add products that constitute significant derivatives of regulated commodities.
In particular, the following are newly excluded from the scope of the EUDR:
- bovine hides, skins and leather;
- retreaded tyres;
- soya beans intended for sowing;
- products made of vulcanised rubber;
- conveyor or transmission belts; and
- seats for aircraft and motor vehicles.
Conversely, the following, for example, will u:
- soluble coffee;
- selected palm oil derivatives; and
- frozen bovine tongue.
The Commission has established a transitional period for newly included products. The obligations under the EUDR will begin to apply to them only from 30 December 2027, so that the companies concerned have sufficient time to adjust their supply chains and compliance processes.
At the same time, the delegated regulation introduces several important interpretative clarifications. For example, it expressly confirms that samples and products intended exclusively for analysis, examination or testing do not fall within the scope of the EUDR. It also clarifies the treatment of certain waste, used products and specific packaging materials in respect of which doubts had arisen in practice as to whether they fell within the scope of the Regulation.
It should be recalled that, as a delegated act, this regulation will still be subject to scrutiny by the European Parliament and the Council. If no objection is raised, it will enter into force in the course of December 2026.
New Rules for the EUDR Information System
In addition to the changes to the scope of application, the Commission also adopted Implementing Regulation (EU) 2026/1565[2] governing the operation of the EUDR information system through which operators will submit due diligence statements. The technical changes are not merely formal. They respond to experience gained during the pilot operation of the system and are intended to facilitate its practical use.
For example, micro and small primary operators will newly be permitted to use a simplified method of submitting statements. At the same time, rules have been established for cases of temporary unavailability of the system, which are intended to prevent technical outages from making it impossible for companies to comply with their statutory obligations.
Further changes concern the technical specifications of application programming interfaces (APIs), through which larger companies will be automatically connected to their internal ERP or compliance systems. At the same time, the Commission has announced that it will continue to develop the information system and plans to make further functionalities available in the coming months.
Updated Guidance and FAQ
Together with both legal acts, the Commission also formally adopted updated Guidance[3] and a Frequently Asked Questions[4] document, which are now available in all official languages of the European Union. Although these documents are not legally binding, they will be of considerable importance in practice.
They provide an interpretation of a number of provisions of the EUDR which have so far given rise to uncertainties and offer practical guidance on complying with due diligence obligations, determining the status of individual participants in the supply chain and assessing the scope of application of the Regulation. It may be expected that not only companies, but also the competent supervisory authorities of the Member States, will rely on these documents in their decision-making activities.
What Do the New Changes Mean for Companies?
The adopted measures do not represent a change to the fundamental philosophy of the EUDR. The obligation to exercise due diligence, verify the origin of commodities, collect geolocation data, assess deforestation risks and submit due diligence statements remains in place.
However, the new acts significantly clarify which products are subject to the obligations, how companies are to use the information system and how certain provisions of the EUDR are to be interpreted. It may therefore be appropriate for a number of companies to reassess whether their product portfolio actually falls within the scope of the Regulation or whether it will be possible to make use of any of the newly introduced simplifications.
From a compliance perspective, it is also advisable to use the remaining months to review internal processes, contractual relationships with suppliers and the configuration of systems for collecting the data necessary to comply with the obligations under the EUDR.
Although the European Commission has provided companies with greater legal certainty and removed certain administrative obstacles, the EUDR remains one of the most complex pieces of European legislation in the area of sustainability and supply chain responsibility. Timely preparation will therefore continue to be a key prerequisite for the smooth placing of the relevant commodities and products on the European Union market after 30 December 2026.
Should you have any questions regarding the EUDR or related matters, please do not hesitate to contact us.
[2] Commission Implementing Regulation (EU) 2026/1565 of 13 July 2026 amending Implementing Regulation (EU) 2024/3084 as regards the submission of due diligence statements, simplified declarations for micro or small primary operators, contingency arrangements and other measures simplifying the use of the information system
[3] Commission Notice – Guidance document for Regulation (EU) 2023/1115 on deforestation-free products
[4] FAQ on EUDR Implementation
Mgr. Jakub Málek, Managing Partner – malek@plegal.cz
Mgr. Kateřina Musilová, Junior Lawyer – musilova@plegal.cz
30. 7. 2026