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 final product scope adopted in July 2026.

Downstream Companies — Who Collects What (December 2025 Rules)

The December 2025 revision created the downstream operator category and made the regime deliberately light. The practical rule, confirmed by the May 2026 Commission guidance:

1. The operator (importer or producer first placing goods on the EU market) files the due diligence statement and receives a reference number.
2. The first downstream buyer — the company purchasing directly from that operator — must collect and retain the reference number (typically from the invoice), for 5 years. It does NOT have to verify the accuracy of the upstream statement, and it files nothing in the Information System.
3. Everyone further down the chain collects no reference numbers and has no obligation to pass them on — only ordinary supplier/customer records are kept.
4. Export: a downstream company exporting outside the EU is expressly exempt from providing a reference number in the customs export declaration (amended Article 26(4)). A producer-exporter, by contrast, remains a full operator.

So your position per purchase decides everything: buying directly from the DDS-filer → keep the reference number; buying anything else within the EU → no EUDR paperwork at all. The only standing duties are record-keeping and not trading goods you know to be non-compliant.

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 (where they buy directly from an operator).
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 buy directly from an operator: request the due diligence statement reference numbers from your supplier and implement a simple record-keeping system. If you buy further down the chain, only ordinary supplier records are needed.
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.