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Report from
Europe
EUDR simplification cuts compliance cost, but
businesses remain concerned
The European Commission (EC) says amendments to
reduce the administrative burden on companies and
streamline implementation of the EU Deforestation
Regulation (EUDR) introduced since it entered into law in
June 2023 will significantly reduce the cost of compliance.
It makes the statement in its EUDR ‘simplification review’
Report to the European Parliament and Council released
May 4. However, European Woodworking Industries
Confederation CEI-Bois says further ‘targeted
adjustments’ to the Regulation may still be needed.
The EC was tasked with undertaking its simplification
review as part of the EUDR Amending Regulation, backed
by the European Parliament and Council and published in
the Official Journal of the EU on December 23, 2025.
This made a range of changes and pushed back EUDR
implementation a year. Consequently, large and medium-
sized operators and traders placing in-scope commodities
and their derivatives on the EU market must comply from
December 30, 2026, and micro and small primary
operators from June 30, 2027.
A new delegated act also issued by the EC alongside its
Report makes a number of changes to the EUDR product
scope. Now out for consultation, it brings some new
products, including soluble coffee and some plant oil
derivatives, under the remit of the Regulation. At the same
time, it exempts certain others, including leather, retreaded
tyres, product samples, certain packing materials, and used
and second-hand products.
Besides this, the EC says it is not minded to make further
amendments to the EUDR core text and the main focus of
the May 4 Report is on summarising and explaining
previous changes made since 2023 and assessing their
impact in reducing businesses’ administrative burden and
making compliance more straightforward. It also describes
latest updates to the Information System to which in-scope
businesses must upload compliance data. Latest iterations
of the EUDR Guidance and FAQ documents are an added
part of the simplification review package,
“The review concludes that measures introduced in 2024
and 2025, together with the December 2025 amendments
and new simplification measures accompanying this
Report, lead to a substantial reduction in administrative
burden and a considerable simplification for companies
which fall under the scope of the Regulation,” states the
EC Report.
“This reduction is particularly relevant for operators
sourcing from low-risk countries, for micro and small
primary operators, and for downstream actors, notably
through introduction of simplified procedures. The new
measures presented [as part of the review] include
proposed changes to the product scope of the Regulation,
clarifications and simplifications of certain provisions, as
well as updates to the information system [following]
recent legislative changes and to make sure it is as user
friendly as possible.
In order to preserve legal certainty and taking into account
progress made in reducing compliance costs, the
Commission does not consider it appropriate to propose
further amendments to the basic legal text.”
“Today we introduce simplification measures which
together with previous [EUDR] simplification efforts are
expected to reduce annual compliance costs for companies
by about 75%,” said Jessika Roswall, European
Commissioner for Environment, Water Resilience and a
Competitive Circular Economy on May 4. “Our efforts are
fully focused on facilitating implementation in the most
efficient way. We all now need to work towards a
successful application of the law by the end of 2026 and
keep in mind its important objective of reducing
deforestation.”
Besides cutting businesses’ administrative burden, the
December 2025 EUDR Amending Regulation was also
introduced to reduce the load on the EUDR Information
System.
Consequently, the EC’s simplification review Report
explains, it ruled that:
• Only first placers of products on the market [and
EU exporters] will have to submit due diligence
statements to the EUDR information system.
• Only first downstream operators will have to
keep and pass on the reference number of the initial due
diligence statement from their operator supplier.
• Micro and small primary operators will be able
submit a one-off simplified declaration to the EUDR
information system.
• Micro and small primary operators will also have
the option to replace geolocation coordinates for the
source of goods, as was envisaged in the original EUDR
text, with a postal address.
The Report further says the new versions of the EUDR
Guide and FAQ documents take into account latest EUDR
changes and provide further clarification on obligations of
various parties along the supply chain. They also respond
to suggestions from business.
“The Commission took the opportunity to analyse
stakeholder input on the basis of which several additional
operational clarifications were introduced,” says the
Report. “These are grouped into three categories;
simplifying clarifications for the downstream supply
chain; micro or small primary operators; and for all
operators regarding legality,” says the Report.
It also notes that, to further clarify EUDR obligations, a
series of Supply Chain Infographics publications are now
available. The latest editions of these came out on 25
March 2026, with revised infographics for each EUDR in-
scope commodity, including timber and wood products.
They illustrate obligations in terms of undertaking due
diligence and uploading due diligence statements to the
information system of upstream operators. These include
importers, placing relevant products on the EU market
under the customs procedure ‘release for free circulation’;
domestic producers, placing on the market relevant
products produced within the EU; and exporters, exporting
‘relevant products under the customs procedure “export”
that are not already covered by a due diligence statement
or simplified declaration’.
Next in the chain are non-SME downstream operators and
traders. The infographics booklet explains that, although
obliged to register in the Information System prior to
placing goods on the market, following latest EUDR
amendments, they do not themselves have to carry out due
diligence or submit due diligence statements.
The obligation on SME and non-SME ‘first traders and
operators must’ is to keep certain information related to
relevant products they place or make available on the
market or export. That includes due diligence system
reference numbers or declaration identifiers received from
operators.
Subsequent downstream operators and traders must keep
records of their suppliers and downstream operators and
traders to which they have supplied products. Also
explained are the one-time simplified declarations micro
and small primary operators can make to the information
system, the obligations of upstream operators to provide
customs with due diligence statement numbers or
identifiers, and requirements for ‘authorised’
representatives.
The EC Report notes that, during the EUDR consultation
process, some stakeholders urged introduction of a ‘no-
risk’ category for supplier countries under the
Regulation’s illegality risk country benchmarking process.
This has not been actioned. But the Report does highlight
that more countries than originally envisaged have been
categorized as low risk, a total of 140, while around 50 are
classed as standard risk. Four, Belarus, Myanmar, North
Korea, and Russia, are categorised high risk. Due
diligence undertaken by EUDR in-scope companies
adjusts according to the supplier country risk ranking, as
does the level of checks on goods by EUDR national
competent authorities.
The EC Report says latest changes made in the EUDR
Information System in response to stakeholder requests
include providing the option of ‘voluntary grouping’ of
due diligence system statement reference numbers when
uploading data.
“Overall, improvements will ensure the System is ready to
support the smooth application of the Regulation,” says
the EC.
In another response to feedback, the EC will establish a
centralised repository of relevant national legislation in
producer countries that in-scope commodities must
comply with to verify legality under the EUDR. There
will also be a repository ‘on certification schemes
applicable to EUDR-relevant commodities’.
The EC Report states that, even before implementation,
the EUDR is influencing supplier country forest policy.
“Countries are preparing for the EUDR, often using it as a
catalyst to strengthen traceability systems and
sustainability initiatives across commodity supply chains
and to improve forest and agricultural monitoring and
governance,” it states.
“These positive effects have been documented in recent
research, demonstrating growing synergies between
government and private sector initiatives worldwide.
A report by Forest Trends indicates that, as of February
2026, at least 25 producer countries are implementing over
60 government-led initiatives linked to EUDR
compliance.”
On 27 April 2026, CEI-Bois signed a statement with 10
other trade bodies representing EUDR in-scope
commodity using and trading sectors urging further
revision of the Regulation. It said that despite the latest
amendments in December 2026, there were still
‘fundamental flaws in the EUDR’s design and
implementation [strategy]’.
“These include lack of legal certainty, unrealistic
compliance requirements and administrative burdens,”
said the statement. “These risk causing market disruption,
including supply shortages, increased costs and reduced
competitiveness for EU sectors, while failing to effectively
address drivers of deforestation.”
Asked for a response to the simplification review Report,
CEI-Bois said:
“From a first reading, it appears a number of key issues
previously raised by the sector have been duly
acknowledged by the EC. This represents a positive signal
and reflects the constructive dialogue maintained
throughout the process.
“However, some concerns remain. In particular,
clarification regarding the possibility for the same entity to
qualify both as an operator and as a first downstream
operator, [which] may inadvertently place certain
companies at a disadvantage. This is especially relevant
for vertically integrated operators that harvest timber
themselves, process it into sawn wood, and then place it
on the market.
Under the current interpretation, such companies would no
longer benefit from a ‘dual role’ status. Instead, they
would be required to carry out full due diligence and
transmit the corresponding information to clients. This
risks creating an uneven playing field compared to other
operators and could introduce additional administrative
burdens for integrated business models.”
CEI-Bois concluded that further clarification, and, where
appropriate, targeted adjustments, may be necessary to
ensure a fair and workable implementation across the
sector. It said this was a preliminary assessment and that
it would develop a ‘more comprehensive position’, after
canvassing members’ views, at a meeting on May 18.
See:
https://environment.ec.europa.eu/document/download/a3c5c3a0-
232e-43c4-b0b8-
1eecb1df45c7_en?filename=Report%20from%20the%20Commi
ssion%20to%20the%20Council%20and%20Parliament%20on%
20the%20EUDR.pdf
and
https://ec.europa.eu/commission/presscorner/detail/en/ip_26_941
and
https://ec.europa.eu/info/law/better-regulation/have-your-
say/initiatives/18053-Deforestation-proposal-to-amend-and-
simplify-the-rules-and-make-technical-fixes-to-Annex-I_en
and
https://ec.europa.eu/commission/presscorner/detail/en/ip_25_293
9?.com=
and
https://eur-lex.europa.eu/legal-
content/EN/TXT/HTML/?uri=OJ:L_202502650
and
https://green-forum.ec.europa.eu/nature-and-
biodiversity/deforestation-regulation-implementation/eudr-
cooperation-and-partnerships/country-classification-list_en
and
https://environment.ec.europa.eu/publications/faq-eudr-
implementation_en
and
https://green-forum.ec.europa.eu/publications/guidance-
document-regulation-eu-20231115-deforestation-free-
products_en
and
https://environment.ec.europa.eu/publications/eudr-supply-chain-
infographics-3rd-edition_en
and
https://www.cei-
bois.org/_files/ugd/5b1bdc_30ad1fc28a6843e2988f873b4f6c59fe
.pdf
Businesses responding to EUDR
According to the latest Forest 500 report, businesses
linked to trade in forest risk commodities in the
international market have already ‘responded tangibly’ to
the prospect of EU Deforestation Regulation
implementation.
The annual report is produced by the non-profit Global
Canopy which advises business and investment
organisations on strategies to minimise their implication in
deforestation. It assesses the actions of the 500 companies
globally with the greatest influence on commodity-driven
deforestation through production and sourcing of nine
forest-risk commodities including timber, cocoa, coffee,
leather, palm oil, soy and rubber. All of these are in the
EUDR’s scope.
Global Canopy said that the latest report, posted in April,
‘reveals that the upcoming EUDR has already shaped
business expectations, galvanized investment and driven
supply chain action by some of the world’s most
influential companies, even before its implementation’.
The report states that in 2025, the number of companies
with public evidence of a traceability mechanism – a key
EUDR requirement – increased for eight of the nine Forest
500 commodities. It also says that 68 (14%) of the
companies assessed cite the EUDR in public documents
related to action on forest loss and 44, cite it as a ‘driver
for action on traceability mechanisms’ taken last year.
“The data points to companies gearing up for the prospect
of the EUDR,” said Chloe Rollscane, Research Associate
at Global Data. “As Forest 500 relies solely on public
disclosures by companies, this is likely just the tip of a
bigger iceberg of corporate decisions taken in private. It
shows the positive influence that regulation can have and
why sustained leadership by governments in key markets
like the EU and UK is so urgently needed.”
At the same time, the report says that progress in terms of
corporate action on deforestation more broadly remains
‘uneven and significant gaps persist’. It categorises
businesses as leaders, late majority and laggards. Of the
total assessed, 19 (4%) are classed as leaders in the 2025
edition. These have ‘strong deforestation commitments
for all the commodities assessed and report significantly
stronger implementation than most’. Global Canopy urges
the EU to keep to its current EUDR implementation
deadline and maintain its rigour.
See -
https://globalcanopy.org/
and
https://forest500.org/publications/forest-500-data-shows-
regulation-is-driving-corporate-action-on-deforestation/
Driving positive tropical timber perceptions to
strengthen forest governance
The UK government-backed Forest Governance, Markets
and Climate (FGMC) programme has unveiled a new
website and communications strategy. This was marked
with an event for NGOs and other communicators, where
one of the speakers, David Hopkins CEO of Timber
Development UK, urged dissemination of more positive
stories about the tropical timber industry to add value to its
products and incentivize and underpin forest governance
improvement.
The FGMC is a programme of the UK Foreign &
Commonwealth Development Office. Its objective is to
help improve stewardship of tropical forests in the Global
South by bringing together governments, businesses, civil
society and communities ‘to make informed decisions and
develop solutions that are both equitable and fair’.
“This means supporting national processes that help
resolve conflicts in the forest sector, leading to laws
shaped by citizens as well as policy makers and
agreements that are seen as fair and legitimate,” says the
FGMC website. “It also means promoting reforms in
consumer markets that favour legally produced and
sustainably managed forest commodities, showing how
demand for responsible products can help strengthen forest
governance in tropical producer countries.”
It adds that its ‘Community of Practice’ also acts as a
platform for stakeholders to connect, share knowledge and
collaborate on important forest governance issues.
The FGMC has been operating for over ten years. Projects
in that time include helping indigenous peoples and local
communities (IPLC) secure clear and enforceable forest
rights in countries such as Ghana, Liberia and the
Republic of Congo. It has also supported forest control
improvement and reduced deforestation, including in
Indonesia, and improvements in forest revenue collection
in countries including Ghana and Liberia.
In its aim to advance timber governance in tropical
countries it has backed efforts to develop better regulation,
enforcement, and traceability systems. It also supports
governance reforms that facilitate access to new revenue
streams for protecting forests, such as carbon finance.
Speaking at the communicators event, David Hopkins said
that still too often the message about tropical timber from
the media, policy makers and NGOS is just to stop using
it.
“They reinforce the negative opinion of tropical timber in
the marketplace. That negative perception may not be
entirely without foundation. But there are a lot of good
things happening in the tropical timber sector and in
tropical forest governance and to constantly repeat those
negative messages can undermine progress,” he said.
“It reduces the value of forest products and the forest
resource and reduces the amount of money going back to
those forests and the people that live from them. This can
incentivize other people to decide to do something more
valuable with forest land. And whatever you think of the
timber industry, it is the only industry that requires a
presence of trees. Other business models for forest land
require absence of trees.”
He added that what is needed to help encourage forest
governance improvement in tropical regions is positive
stories.
“And we know through the work of FGMC with tropical
countries, and through our work at TDUK, that those
stories exist. There are a lot of good examples around the
world we can draw on,” said Mr Hopkins “We need
positive storytelling, marketing and branding to reinforce
positive perceptions – and, to maximise its value for
producers, within that we should be promoting the fact
that tropical timber is a quality material, a high end luxury
product. It should not be competing in the market with
MDF.”
Reinforcing a positive image of tropical timber in turn
would encourage policy makers and producers in tropical
countries to support forest governance improvement and
enforcement. It would effectively create a virtuous circle.
“Policy makers are inspired by positive stories,” said Mr
Hopkins. “And if they are as a result encouraged to
further strengthen forest governance, as the experience of
other countries has shown, including in the US and
European countries, this ultimately leads to forest growth.”
He concluded that there is a prominent role for FGMC
communications in encouraging positive perceptions of
tropical timber given that tropical countries lack a central
communications operation.
“And businesses in the rest of the supply chain can benefit
from that structured messaging,” he said. “This has
potential to increase market demand that pushes more
money back through supply chain which, in turn, can have
tangible benefits on the ground in terms of forest
governance.”
See- https://fgmc.org.uk/en/
and
https://timberdevelopment.uk/
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