Key points you need to know
- The Commission has not proposed changes to the EUDR’s core legal basis. Changes are being delivered through revised guidance, updated FAQs, IT system improvements, and targeted secondary legislation.
- The headline figure of a 75% reduction in compliance costs are mainly concentrated at the SME and downstream end of the supply chain.
- The due diligence obligations have become concentrated at the level of first-placer operators, with lighter requirements for downstream operators.
- The application dates are unchanged, remaining at 30 December 2026 for large and medium-sized operators, and 30 June 2027 for most micro and small operators.
- The window to build compliant systems, supplier relationships, and documentation is now, as no further substantive relief is coming.
On 4 May 2026, the European Commission published its long-awaited simplification review of the EU Deforestation Regulation. The report’s headline figure of a projected 75% reduction in annual compliance costs has already generated significant coverage. But before that number shapes how your business responds, it is important to understand the new implications and what remains unchanged.
The new package does not soften the regulation
Delays and lobbying from industry stakeholders had created some expectations that the EUDR may be weakened, but the May 2026 package dispels this. The Commission has not reopened the EUDR’s core legal text. By choosing to work with guidance updates, delegated acts, IT system changes, etc., the Commission has avoided reopening a legislative file that may have been vulnerable to further amendment. Instead of the EUDR being rolled back, it has been made more practical to apply.
Understanding the 75% reduction figure
The Commission’s projection of a 75% reduction in annual compliance costs has garnered attention, but it requires context. Importantly, the comparison point is with the original 2023 regulation. Since then, there have been two rounds of amendments, successive rounds of guidance that have reduced friction across the system, and a country risk classification exercise that has designated many more countries as low risk.
Downstream operators and traders whose products are already covered by upstream compliance benefit the most. The update means such players’ role is now limited to retaining supplier information and acting on warning signs, rather than conducting their own due diligence at the level of first placers. Micro and small primary operators in low-risk countries benefit through a one-time, simplified declaration now, instead of repeated due diligence statement submissions. They can also provide postal addresses as a substitute for geolocation coordinates (provided that it clearly corresponds to the geographic location of the plots of land).
Large and medium-sized ‘first placers’
The heaviest due diligence responsibilities now sit with the first operators placing a product on the EU market or exporting it. The full three-step process of information gathering, risk assessment, and risk mitigation continues to apply to such players.
What the guidance clarifies
The May 2026 package contains an updated guidance document, which provides clarity on several key areas.
Legality expectations
Legality evidence is considered proportionate to risk. In lower-risk supply chains, operators are not expected to compile exhaustive legal documentation for every plot of land as a matter of routine. An initial examination of available information can determine whether a deeper investigation is needed.
Geolocation requirements
Plot-level geolocation remains mandatory for most operators, but micro and small primary operators may now use a postal address in place of precise geolocation coordinates, provided that it clearly corresponds to the geographic location of the plots of land or, in the case of cattle, the relevant establishment.
Supply chain complexity
Supply chain complexity can be viewed as a risk signal. The more processors, intermediaries and countries of production involved, the harder it becomes to trace a product back to the relevant plot of land, and the higher the compliance risk. This matters particularly for businesses sourcing across multi-tier supply chains where visibility beyond the first tier is limited.
Certification schemes
Certification schemes are acknowledged as useful inputs to the risk assessment process. However, using a certification or third-party verification scheme still does not remove the operator’s due diligence obligation. There is no green channel. Certification can support a risk assessment, but the operator remains responsible for the conclusion.
Downstream operators
Downstream operators who are not first placers are not expected to re-check upstream compliance, but instead retain due diligence statement references and pass them down the chain. While less active, they still hold responsibility; their obligation is to collect and retain information and to act if warning signs emerge. For these downstream players, third-party certification may be relied on, but it should not be mistaken for a substitute for due diligence when it is required.
Product scope is also shifting
The draft delegated act published alongside the report also proposes targeted changes to the list of in-scope products. Certain downstream derivatives are proposed for addition, including soluble coffee and specific palm oil derivatives. Proposed removals include leather, cattle hides, and retreaded tyres, along with broader exemptions for packaging materials, product samples, waste, and second-hand goods. The public feedback period for these closes on 1 June 2026.
What does it all mean for your business?
The simplification package reduces friction at the SME and downstream end of the supply chain while leaving the core obligations on first placers fully intact. The deadlines have not moved, and the legal requirements have not changed. Authorities are still actively preparing for enforcement from day one of application. The window between now and December 2026 is the time to build the systems, supplier relationships, and documentation that EUDR compliance requires.
How DoubleHelix Can Help
DoubleHelix supports businesses with EUDR due diligence by working directly with both clients and their upstream suppliers, in local languages, on the ground, to identify problems and implement practical solutions before they become audit findings.
If you are unsure what the May 2026 package means for your supply chain, speak to our team. We can help you establish where you stand, what your obligations are, and what needs to happen before December 2026.
Speak to us about EUDR due diligence and supply chain verification.