EUDR deadlines 2026/2027 explained for SMEs

The dates at a glance

Size classes follow Article 3 of Directive 2013/34/EU. A small undertaking does not exceed two of: €7.5 million balance sheet, €15 million net turnover, 50 employees (thresholds as amended in 2023). Check the current figures for your financial year.

How we got here

• June 2023: Regulation (EU) 2023/1115 enters into force with application from 30 Dec 2024 (30 Jun 2025 for micro and small enterprises).
• December 2024: Regulation (EU) 2024/3234 postpones application by twelve months.
• December 2025: Regulation (EU) 2025/2650 (published 23 Dec 2025, in force 26 Dec 2025) postpones again – to 30 Dec 2026 and 30 Jun 2027 – and simplifies obligations along the supply chain.
• May–September 2026: The Commission completes its simplification package: updated guidance (C/2026/3896), an Implementing Act for the Information System, and Delegated Regulation (EU) 2026/2102 on the product scope, in force since 18 Sep 2026. The application dates above were not changed.

Micro and small enterprises

The later date of 30 June 2027 applies to operators that are natural persons or micro or small undertakings, provided they were established as such by 31 December 2024. The exception is wood: for products in the Annex to the old EU Timber Regulation – sawn wood, furniture, pulp and paper and others – micro and small operators start on 30 December 2026 like everybody else. They have been under EUTR due diligence since 2013.

The later date only moves the start. The content of the obligations – geolocation of every plot, deforestation-free after 31 Dec 2020, legal production, records for five years – stays the same.

Simplified declaration for primary producers

Regulation (EU) 2025/2650 created the “micro or small primary operator” (Art. 2(15a)): a natural person or micro/small undertaking established in a country classified as low risk, placing on the market products it has itself grown, harvested or raised there. Instead of a DDS per shipment it submits a one-time simplified declaration (Art. 4a) and may give the postal address of its plots or establishment instead of coordinates, if the address clearly corresponds to the location.

Example: a small Turkish company that harvests and sells wood from its own forest land can use this route – Türkiye is classified as low risk by Implementing Regulation (EU) 2025/1093. (Hazelnuts, often asked about, are not an EUDR commodity at all.)

Downstream operators and traders

After the 2025 amendment, downstream operators and traders no longer submit their own DDS. The first downstream operator or trader collects and keeps the DDS reference numbers or simplified-declaration identifiers from its upstream suppliers; further down the chain, companies keep records of their suppliers and customers. Downstream operators and traders that are not SMEs must register in the Information System.

Product scope changes in 2026

The seven commodities remain: cattle, cocoa, coffee, oil palm, rubber, soya and wood. Delegated Regulation (EU) 2026/2102 changed the products in Annex I: since 18 Sep 2026, cattle hides, skins and leather (ex 4101, ex 4104, ex 4107) and several rubber articles are out of scope; soluble coffee, certain palm-oil derivatives and frozen cattle tongues come in from 30 Dec 2027. Printed products of Chapter 49 were already removed by Regulation (EU) 2025/2650.

What to do before your date

1. Map which of your products fall under Annex I (by HS code) and which role you have for each: operator, downstream operator or trader.
2. Ask every supplier for plot geolocation now – collecting polygons from smallholders takes months, not weeks.
3. Test the data: run it through the TRACES GeoJSON rules (see our GeoJSON guide) and a deforestation screening against the 31 Dec 2020 cut-off.
4. Register in the EU Information System and file a test DDS before your application date.

Questions & answers

This guide summarises the legal texts as of 16 October 2026. It is not legal advice; the regulations published in the Official Journal are authoritative. Screening service – not a certification and not legal advice. Due diligence and the due diligence statement (DDS) remain the operator’s responsibility.