What Changed, What was simplified, and What it means for your bussiness.
On 4 May 2026, the European Commission published the Simplification Report on Regulation (EU) 2023/1115. including a ๐๐ซ๐๐๐ญ ๐๐๐ฅ๐๐ ๐๐ญ๐๐ ๐๐๐ ๐ฎ๐ฅ๐๐ญ๐ข๐จ๐ง updating the list of relevant commodities and products under Annex I.
For more information, please refer to : Simplification Report EUDR , ๐๐ซ๐๐๐ญ ๐๐๐ฅ๐๐ ๐๐ญ๐๐ ๐๐๐ ๐ฎ๐ฅ๐๐ญ๐ข๐จ๐ง
This report outlines the simplification measures introduced since the EUDR entered into force in June 2023 and evaluates their impact on reducing administrative burdens while preserving the Regulationโs core objective: ensuring deforestation-free supply chains. Particular attention is given to micro and small operators.
Key Areas of Simplification and Clarification
1 The Commission has updated the Guidance and Frequently Asked Questions to address key stakeholder concerns
2 The product scope has been refined (clearer HS codes & Product Definitions)
3 The Report also outlines further developments of the Information System
4 The Report presents the planned establishment of new trade facilitation tools
The Commission has updated the Guidance and Frequently Asked Questions
Summary of items that have been simplified or clarified in the guidance document. For more information, please click here FAQ pm EUDR Implementation
Main Guidance Clarifications
Definitions Clarified
The updated guidance provides more precise definitions for:
- โPlacing on the marketโ
- โMaking available on the marketโ
- โExportโ
- โOperatorโ
- โDownstream operatorโ
- โMicro or small primary operatorโ
- โTraderโ
Date of effect and time-frame for application
- For operators, downstream operators and traders, as well as on competent authorities including those in Articles 3 to 13, Articles 16 to 24, Articles 26, 31, and 32, apply from 30 December 2026.
- For operators that were established as micro-undertakings or small undertakings by 31 December 2024 the obligations in Articles 3 to 13, Articles 16 to 24, Articles 26, 31 and 32, apply from 30 June 2027
Due diligence obligations
Further clarification has been provided on:
- Risk assessment and mitigation obligations under Articles 10 and 11
- Negligible risk interpretation
- Simplified due diligence for sourcing from low-risk countries
- Obligations for SMEs and downstream operators
- Interaction with other EU legislation, including the Corporate Sustainability Due Diligence Directive (CSDDD) and Forced Labour Regulation
- Risk assessment and risk mitigation (Article 10 and 11)
- Negligible risk
- Obligations for micro or small primary operators
- Obligations for downstream operators and traders
- Simplified due diligence, i.e. sourcing from low-risk countries
- Interplay with Corporate Sustainability Due Diligence Directive and the Forced Labour Regulation
Supply Chain Complexity
The Commission has provided additional guidance on how to assess supply chain complexity, particularly relevant for commodities with multiple intermediaries such as cocoa and coffee.
Legality Requirements
Clarifications include:
- Applicable producer-country legislation
- Land rights
- Indigenous rights
- Anti-corruption obligations
- Documentation expectations
Product Scope Clarifications
Important clarifications now cover:
- Packaging and packing materials
- Waste, recycled, and recovered products
- Composite products
- Agricultural and agroforestry systems
Certifications
Certification schemes and third-party verification remain useful support tools but do not automatically guarantee EUDR compliance
2 Product Scope Refinement
- ๐๐ซ๐จ๐ฉ๐จ๐ฌ๐๐ ๐๐ก๐๐ง๐ ๐๐ฌ ๐ข๐ง๐๐ฅ๐ฎ๐๐
- Soluble coffee (CN 2101 11) added to scope
- Expanded inclusion of additional palm-oil derivatives and downstream processed goods
- Proposed removal of leather and retreaded tyres
- Clear exclusions for samples, selected packaging materials, used/second-hand goods, and waste streams
- Stronger definitions for composite products, packaging, waste, and downstream goods
- These developments are designed to create a more consistent and workable framework for businesses while preserving the EUDRโs core sustainability objectives
3 The Report also outlines further developments of the Information System
The Simplification Report emphasizes continued upgrades to the EUDR Information System, including:
- Improved geolocation functionality
- Better referencing of upstream DDS submissions
- Enhanced product-level data fields
- Expanded API capabilities for larger operators
These updates are intended to improve operational efficiency, traceability, and system interoperability.
4 New Trade Facilitation Tools
A significant upcoming development is the planned creation of an EU-managed repository of producer-country legislation. This tool is expected to centralize legal references related to:
- Land use
- Forest protection
- Indigenous rights
- Agricultural legality
This could substantially reduce the legal research burden on operators.
What This Means for Businesses
Updated Implementation Timeline
Businesses should note the corrected implementation dates:
- Most obligations on operators, downstream operators and traders, as well as on competent authorities including those in Articles 3 to 13, Articles 16 to 24, Articles 26, 31, and 32, apply from 30 December 2026
- For operators that were established as micro-undertakings or small undertakings by 31 December 2024 the obligations apply from 30 June 2027
Strategic Priorities
Companies should use this additional clarity to:
- Map supply chains comprehensively
- Collect geolocation coordinates
- Strengthen legality verification
- Invest in digital traceability systems
- Align suppliers, cooperatives, and exporters with EUDR obligations
This is particularly critical for high-complexity commodities such as cocoa, coffee, palm oil, soy, cattle, rubber, and wood-derived products.
What is still pending ?
- Final EU Benchmarking List (Low-, Standard-, High-Risk Countries)
- Full deployment and operational maturity of the EUDR Information System
- Practical rollout of trade facilitation tools
NHSuperfoods: Working HandโinโHand With Origin Partners to Be Fully EUDRโReady
NHSuperfoods is actively preparing for the EUDR by working closely with its network of farmers, cooperatives, and exporter partners across Peru, Ecuador, and other key origins. Together, we are strengthening traceability, improving geolocation data collection, and aligning postโharvest practices with the new legal and sustainability requirements. This collaborative approach ensures that every actor in the supply chain โ from smallholder farmers to certified processors โ is ready for the regulationโs full implementation.
If you are looking to secure EUDRโcompliant cacao or coffee ingredients and avoid penalties, delays, or supplyโchain disruptions, NHSuperfoods is your trusted partner. We manage the full complexity of compliance, documentation, and origin verification, ensuring every product meets the highest standards of safety and sustainability.
With our reliable network in Peru and Ecuador and our commitment to 100% traceability, we help you protect your brand and keep your operations running smoothly. Contact us to secure compliant stock and strengthen your supply chain with confidence.
- Disclaimer : The information provided in this document is for informational purposes only. While the content has been compiled from sources believed to be reliable, no representation or warranty, express or implied, is made regarding its accuracy, completeness, or correctness. Readers are responsible for reviewing, analysing, and verifying all regulatory requirements independently to avoid misunderstandings. The information and statements herein are shared in good faith and should not be considered legal advice.