EUDR Guide for SMEs — Simplified Obligations and Deadlines

EUDR for Small and Medium-Sized Enterprises

Regulation (EU) 2023/1115 recognizes that SMEs have limited resources and grants them certain accommodations. However, SMEs are not exempt from EUDR obligations — they benefit from a simplified regime and extended deadlines.

Who Qualifies as an SME?

The SME definition follows Commission Recommendation 2003/361/EC:

Category	Employees	Annual Turnover	Balance Sheet Total
Micro-enterprise	< 10	≤ EUR 2 million	≤ EUR 2 million
Small enterprise	< 50	≤ EUR 10 million	≤ EUR 10 million
Medium enterprise	< 250	≤ EUR 50 million	≤ EUR 43 million

Important: The key distinction in EUDR is between operators and traders. SME accommodations primarily apply to traders who are SMEs. Operators, regardless of size, have full due diligence obligations.

Extended Deadline

Following the December 2025 targeted revision of the EUDR, deadlines have been pushed back by a further 12 months and a new lighter regime has been created for small and micro operators (not just traders) handling non-timber commodities:

• Large and medium operators and traders: 30 December 2026
• Small and micro operators (non-timber): 30 June 2027
• Small and micro operators (timber): 30 December 2026 (same as large)

Check EUDR.today for the latest deadline updates and the April 2026 simplification package.

Simplified Obligations for SME Traders

Traders who are SMEs have a simplified due diligence regime. Instead of carrying out their own full due diligence system, they must:

1. Collect and retain information about their suppliers and customers.
2. Retain the reference numbers of due diligence statements issued by upstream operators.
3. Make this information available to competent authorities upon request.

In other words, SME traders rely on the due diligence performed by the operator who first placed the product on the market. They need only ensure traceability.

What Is NOT Simplified

Be aware — the following obligations apply in full to SMEs as well:

• The prohibition on placing non-compliant products on the market (from deforestation or violating the country of production's legislation).
• The obligation to retain documents for 5 years.
• Liability if the SME trader has knowledge or grounds to suspect non-compliance.

Practical Steps for SMEs

1. Check whether your products are covered by EUDR — consult the list of covered commodities.
2. Determine your status — are you an operator (first to place the product on the EU market) or a trader (purchasing from an operator who has already placed the product)?
3. If you are an SME trader: request the due diligence statement reference numbers from your supplier and implement a simple record-keeping system.
4. If you are an SME operator: your obligations are the same as for large operators. Consult the due diligence guide and the compliance checklist.
5. Start early — even though the deadline for small/micro non-timber operators is June 2027, collecting data from suppliers takes time, and large/medium operators must be ready by December 2026.

Resources for SMEs

The European Commission has published specific guidance for SMEs, and some Member States offer dedicated assistance. Also consider EU funding programmes for supply chain digitalization, which may cover part of the implementation costs. For a complete understanding of the legislative framework, visit EUDR.live.

SMEs in the wood sector can benefit from FSC/PEFC group certification — a solution that allows multiple small companies to share certification and audit costs, significantly reducing the financial barrier. Learn more at sustainability.today.