Free tool
EUDR Obligations Checker
The 2026 simplification changed who does what. Tell us a few things and see exactly what applies to you, and by when. You get a plain-English verdict, your deadline, and a tailored checklist, all on this page.
Not sure you are even in scope? Start with the scope checker.
Step 1 of 5
The 2026 simplification
What changed, by role
The May 2026 simplification package re-wrote who does what under the EUDR. It is a clarification within the existing timeline, not another delay. Here is each role in plain English.
TL;DR
First operator
You first import or place the product on the EU market, or export it.
Runs full due diligence (collect information including geolocation, assess risk, mitigate it) and files a due diligence statement in the EU Information System built on TRACES. The 2026 package kept this duty but allows annual rather than per-consignment filing.
Downstream operator or trader (medium or large)
You buy a product already on the EU market, then resell or use it.
Generally does not file its own statement. It collects and keeps the upstream reference numbers, which ordinary invoices can carry, and passes them on down the chain. Records are kept for five years.
SME trader (micro or small)
You are a micro or small enterprise buying something already on the market.
The lightest route. Only needs to collect and keep supplier and buyer records for five years. The duty to actively pass reference numbers on was removed for businesses this size.
Micro or small first operator from a low-risk country
You are a micro or small enterprise and the first to bring the product in, from a low-risk country.
May use a one-time simplified declaration instead of a per-consignment statement, may give a verifiable postal address instead of GPS geolocation, and may appoint an authorised representative such as a cooperative.
Why the role question matters most
Before 2026, many companies further down the supply chain feared they would have to repeat the full due diligence already done upstream. The simplification package made clear they do not. The company that first places an in-scope product on the EU market, the first operator, carries the substantive work: collecting information including geolocation, assessing and mitigating risk, and filing the due diligence statement. Everyone downstream of that mostly handles paperwork. European Commission, deforestation regulation implementation
For first operators, the package kept the core duty but eased the rhythm of it: you may file annually rather than for every single consignment, and micro and small first operators sourcing from low-risk countries can use a one-time simplified declaration, a verifiable postal address in place of GPS geolocation, and an authorised representative such as a cooperative. Regulation (EU) 2023/1115, as amended
For micro and small traders, the change went furthest: they now only collect and keep their supplier and buyer records for five years, and the duty to actively pass reference numbers on was removed for them. Country risk still matters on top of all of this. Low-risk origin unlocks simplified due diligence and the lowest inspection rate, around 1 percent, while high-risk origin brings enhanced scrutiny and the highest rate, around 9 percent. European Commission, EUDR overview
One part of scope is still moving
Obligations questions people ask
Do downstream operators file a DDS?
Generally no. After the 2026 simplification, a downstream operator or trader that buys a product already on the EU market does not file its own due diligence statement. Its job is to collect and keep the reference numbers from the upstream operator who already filed, which ordinary invoices carrying the reference number can satisfy, and pass those numbers on down the chain. The company that first places the product on the EU market, the first operator, is the one that files.
What changed for SMEs in 2026?
A lot, in their favour. Micro and small traders now only need to collect and keep their supplier and buyer records for five years; the duty to actively pass reference numbers on down the chain was removed for them. Micro and small first operators sourcing from low-risk countries get the lightest route of all: a one-time simplified declaration instead of a per-consignment statement, the option to give a verifiable postal address instead of GPS geolocation, and the ability to appoint an authorised representative such as a cooperative.
What is the difference between a first operator and a trader?
A first operator is the company that first imports or places an in-scope product on the EU market, or exports it. It carries the fullest duties: collect information including geolocation, assess and mitigate risk, and file a due diligence statement. A trader buys a product that is already on the EU market and resells it. After 2026 a trader mostly collects, keeps and passes on the existing reference numbers rather than filing anything itself.
What is my EUDR deadline?
The dates are confirmed in law after the second delay agreed in December 2025. Medium and large operators and traders must comply from 30 December 2026. Micro and small enterprises have until 30 June 2027, provided they were established as micro or small by 31 December 2024. These dates are about when the obligations start to apply, not a one-off filing date.
This is guidance to help you understand the EUDR, not legal advice. For decisions specific to your business, confirm with the official sources we link or a qualified adviser.
Sources
- [1]Regulation (EU) 2023/1115 (EUDR), consolidated text on EUR-Lexretrieved 5 Jun 2026
- [2]European Commission, Regulation on deforestation-free productsretrieved 5 Jun 2026
- [3]European Commission, deforestation regulation implementation (simplification)retrieved 5 Jun 2026