Acting on the EUDR Simplification Package — Operator Checklist (Updated July 2026)

Acting on the EUDR Simplification Package — Updated for the 13 July 2026 Adoption

On 4 May 2026, the European Commission published its EUDR simplification package — press release IP/26/941. Four instruments arrived together: a report to the Parliament and Council, an updated guidance document, updated FAQs, and a draft delegated act on product scope. In parallel, the Commission updated the implementing act on the EUDR Information System.

Update, 13 July 2026: the delegated act on product scope and the implementing act on the Information System have been adopted, with a broader exclusion list than the May draft. The Information System relaunched in June 2026 and the guidance is now available in all EU languages. The checklist below is updated accordingly.

This page is the operator checklist: the things to do in your compliance programme now. For the news framing see eudr.today; for the legal walkthrough see eudr.live.

The 8-step operator checklist

Step 1 — Re-map your product list against the final Annex I (adopted 13 July 2026)

Run a line-by-line check of the adopted delegated act against the HS codes you import, manufacture or trade. Three categories of change:

• New in scope, compliance from 30 December 2027 — soluble coffee, certain palm oil derivatives (including oleochemicals used in soap) and frozen cattle tongues. If you handle these and were treating them as out of scope, you need a full due diligence procedure (Articles 4–10) by that date.
• Removed from scope — cattle hides, skins and leather; retreaded tyres; soybeans for sowing; vulcanised rubber articles; conveyor and transmission belts; aircraft and motor vehicle seats. If you were preparing DDS workflows for these, stand them down.
• Exempted — product samples, packaging material used purely as packaging, marketing materials, correspondence items, used and second-hand products, waste. Document the basis for treating shipments as exempt; auditors will ask.

Step 2 — Verify your downstream position per supply

Only the first downstream buyer after the operator collects and retains the DDS reference number; companies further down keep ordinary supplier records only, and downstream exporters are exempt from providing reference numbers at export customs. Map each purchase: direct-from-operator supplies need a reference-number capture step in procurement; everything else needs none. See the SME and downstream guide.

Step 3 — Refresh your due diligence SOPs against the updated guidance

The updated guidance document and updated FAQs address topics most often raised by stakeholders. Two areas matter most for SOP updates:

• Downstream simplified due diligence (introduced December 2025) — the guidance confirms the passive nature of the regime: the first downstream operator collects reference numbers without any duty to verify their accuracy, and nothing cascades further down the chain.
• Very simplified regime for micro and small primary operators — what qualifies as "primary", what the simplified declaration contains, and how the regime interacts with low-risk country sourcing.

Also re-read the e-commerce and geolocation sections — both got significant new guidance. The guidance document is now available in all EU languages, including Romanian — useful for training non-English procurement teams.

Step 4 — Decide whether to switch to the simplified declaration form

The updated implementing act on the Information System adds a simplified declaration form for micro and small primary operators, aligned with the existing DDS format. If you are eligible (small or micro, primary operator), assess whether to use it — it materially reduces submission burden but the eligibility test is fact-specific.

Step 5 — Plan IS API changes with engineering

The implementing act adopted on 13 July 2026 fixes the automated application interface specifications for machine-to-machine integration with the EUDR Information System (relaunched June 2026). If you submit DDS volumes through APIs (typical for medium and large operators), schedule the engineering work now:

• Pull the adopted API specification published with the implementing act.
• Identify breaking changes versus your current integration.
• Plan a test environment switchover before production rollout.
• Build the contingency plan into your runbook for unplanned IS unavailability.

Step 6 — Evaluate the voluntary grouping feature

The implementing act introduces a voluntary grouping feature. If you ship many similar consignments under shared due diligence (e.g., multiple deliveries from one verified plot bundle), grouping reduces submission overhead. Map your shipment patterns to the grouping rules once published.

Step 7 — Update your low-risk country sourcing process

The simplification report flags planned repositories of producing-country legislation and recognition of certification schemes as forthcoming trade-facilitation tools. Both feed into your Article 10 risk assessment for low-risk country imports. Track Commission publications and add the repositories to your risk-assessment evidence library when available. See also the existing low-risk sourcing guide.

Step 8 — Confirm the deadlines internally

The package does not change application dates. Refresh your compliance roadmap with the confirmed deadlines:

• 30 December 2026 — large and medium companies, plus micro and small in the timber sector.
• 30 June 2027 — other micro and small enterprises (non-timber).

If your project sponsor was waiting to see whether the Commission would push the dates, the answer is now public: it did not. Resource the programme accordingly.

The 75% cost-reduction figure — how to read it

The Commission's headline claim is that the package, taken together with the December 2025 revision, reduces annual compliance costs by about 75% versus the original EUDR. For an operator, the figure is informative but not directly bankable — the realised reduction depends on:

• How much of your portfolio is downstream (eligible for Article 13a simplified DD).
• How much of your sourcing is from countries that will be classified as low-risk.
• Whether you are eligible for the micro/small primary operator simplified regime.
• Whether you can use the voluntary grouping feature for your shipment pattern.
• Whether your producing countries have national databases that feed the IS.

Use the figure in board reporting with these caveats; build your own bottom-up estimate before locking budgets.

What did not change

• The seven commodities. Cattle, wood, cocoa, soy, palm oil, coffee, rubber.
• The cut-off date. 31 December 2020.
• Geolocation. Still required for all production plots.
• Penalties. Up to 4% of annual EU turnover under Article 25.
• The benchmarking system. The first country list was adopted on 22 May 2025 — all EU member states, including Romania, are low risk. First review scheduled for 2026.

Related practical guides

• Due diligence procedure step by step
• SME and micro-enterprise compliance guide
• Sourcing from low-risk countries — simplified DD
• Due diligence statement template