Introduction
As we explained in an earlier article, under EU Regulation 2023/1115 on deforestation-free products (the EUDR), which entered into force on 29 June 2023, any operator or trader who places relevant commodities or their products on the EU market, or exports from it, must be able to prove that the products do not originate from recently deforested land or have not contributed to forest degradation.
In a subsequent update, we reported on the Commission’s proposal — ultimately agreed by the co-legislators in December 2025 — to postpone the entry into application of the EUDR by one year, principally because of concerns over the readiness of the centralised IT system underpinning the regime.
On 4 May 2026, the Commission published its long-anticipated simplification review of the revised EUDR, together with a package of further measures designed to support a smooth and effective entry into application by 30 December 2026. The package is intended to provide additional clarity to economic operators, Member States, third countries, and other stakeholders, while preserving the legal stability and predictability that businesses have been seeking.
In this article, we summarise the key elements of the package and set out our recommendations for in-scope businesses.
The Commission’s Package at a Glance
The package comprises four principal elements:
- A report to the European Parliament and the Council, describing the simplification measures implemented since the EUDR entered into force in June 2023, together with those introduced in the new package. Taken together, these measures are expected to reduce annual compliance costs for companies subject to EUDR obligations by approximately 75% compared to the original Regulation.
- An updated guidance document and Frequently Asked Questions, addressing the topics most frequently raised by stakeholders, with particular focus on the obligations of downstream operators e-commerce, geolocation, and the simplified regime applicable to micro and small primary operators.
- A draft delegated act on the product scope of the EUDR, updating last year’s draft and incorporating stakeholder feedback.
- An updated draft implementing act on the Information System, to be submitted to Member States before adoption, reflecting changes introduced by the revised Regulation and enhancing user-friendliness of the platform.
Key Features of the Simplification Package
Reduction in Administrative Burden
The headline feature of the package is the projected 75% reduction in annual compliance costs for in-scope companies, when measured against the original EUDR baseline. The Commission’s report also flags planned trade facilitation tools, including repositories of legislation of producing countries and certification schemes for EUDR commodities, designed to assist operators with risk assessment and due diligence.
Adjustments to the Product Scope
The draft delegated act incorporates targeted amendments to the EUDR product scope. Notable proposed changes include:
- Additions to scope, such as soluble coffee and certain palm oil derivatives.
- Exclusions from scope, including leather and retreaded tyres.
- Exemptions, covering product samples, certain packing materials, used and second-hand products, and waste.
These proposals are subject to a public feedback period running until 1 June 2026, providing in-scope businesses with an opportunity to comment.
Enhancements to the Information System
The Information System — the readiness of which had been the principal driver of the December 2025 postponement — is being updated to reflect the revised Regulation and to improve usability. The main developments include:
- A simplified declaration form for micro and small primary operators, aligned with the existing due diligence statement format.
- Updated specifications for the automated application interfaces.
- A contingency plan for unplanned unavailability.
- A voluntary grouping feature, introduced in response to requests from the business sector.
The Commission is also working with Member States to ensure that information already held in national databases can be reflected directly in the Information System, with a view to further reducing the burden on micro and small primary operators.
Application Dates
The revised Regulation will apply from 30 December 2026 for large and medium companies, as well as for micro and small enterprises in the timber sector, and from 30 June 2027 for other micro and small enterprises.
Lessons for Irish Business
With the 30 December 2026 deadline now firm, we recommend that in-scope businesses:
- Re-confirm scope under the revised product list: Use the consultation period (running to 1 June 2026) to verify whether your product portfolio is affected by the proposed additions, exclusions, or exemptions, and to consider whether to make a submission.
- Refresh due diligence systems against the updated guidance: The clarifications on downstream obligations, e-commerce, and geolocation should be reflected in internal procedures and, where appropriate, in supplier-facing documentation.
- Revisit supplier and logistics contracts: Ensure that contractual arrangements remain fit for purpose under the final scope, and that warranties, information rights, and termination provisions support compliance.
- Monitor the delegated and implementing acts: Both instruments remain in draft. Final adoption may bring further refinements that should be tracked through to the application date.
Conclusion
With the 30 December 2026 application date now fixed and a clearer picture of scope, guidance, and IT infrastructure, in-scope businesses are well placed to finalise their compliance frameworks. As ever, readiness remains the prudent course.
For more information, please contact John Gaffney or your usual contact in Beauchamps LLP.
