Today, 4 May 2026, the European Commission published a coordinated set of documents intended to ease the path through the EU Deforestation Regulation (EUDR): a Report to the European Parliament and the Council on its simplification review, an updated Guidance Document, the fifth iteration of its Frequently Asked Questions, and a draft Delegated Act amending the list of relevant commodities and products in Annex I. The package arrives roughly eight months before the regulation begins to apply on 30 December 2026, and it addresses many of the practical questions stakeholders have raised since the December 2025 amendment.
Most companies we work with have been preparing for EUDR for some time, mapping in-scope products, building supplier engagement programmes, and planning for the entry into application. The Commission’s package does not change the regulation’s core obligations, and the Commission has explicitly decided not to propose any further amendments to the basic legal text. What it does do is refine the product scope, clarify several provisions that have been difficult to operationalise, and outline how the Information System will accommodate the simplified due diligence model adopted at the end of last year. In this article, we walk through what has been published, the changes that matter most for compliance planning, and where meaningful uncertainty still remains.
What the Commission published
The package has four components, all published on 4 May 2026. The Report to the European Parliament and the Council fulfils the Commission’s mandate under Article 34(1a) of the EUDR to carry out a simplification review. The updated Guidance Document and the fifth iteration of the FAQ together address the topics raised by stakeholders since the December 2025 amendment. The draft Delegated Act, accompanied by a Staff Working Document and an Annex, proposes a refined list of relevant commodities and products and is open for public feedback until 1 June 2026.
The Commission’s headline conclusion is that the legislative changes already adopted in 2024 and 2025, combined with the new measures published this week, will reduce annual compliance costs for in-scope companies by approximately 75 percent relative to the original assessment. On that basis, the Commission has confirmed it will not propose further amendments to the basic legal text. The simplification is being delivered through the Delegated Act, the Guidance and FAQ updates, the Information System, and a set of trade facilitation tools that will follow.
Changes proposed to the product scope
The draft Delegated Act introduces a small number of targeted changes to Annex I: some additions, some removals, and a series of clarifications that close gaps the original product list left open.
On the additions side, the Commission proposes to bring soluble coffee (HS 2101 11 00) into scope, on the basis that excluding extracts, essences, and concentrates while including roasted and green beans creates incoherence in the coffee value chain. Frozen cattle tongues (HS ex 0206 21 00) would be added for similar reasons, aligning the treatment of fresh and frozen forms. A wider set of palm oil derivatives used in oleochemicals manufacturing would also be added, including soaps containing palm oil, addressing a gap that allowed downstream palm oil products to reach the market without due diligence.
On the removals side, the Commission proposes to take cattle hides, skins, and leather (HS ex 4101, ex 4104, ex 4107) out of scope. The reasoning is operational rather than environmental: leather operators have limited commercial leverage to obtain the supplier information the EUDR requires, and the relatively low value of hides within the cattle production economy means the regulation’s traceability mechanisms are difficult to apply consistently. Retreaded tyres would be narrowed in scope so that only the new rubber tread, rather than the full retreaded product, carries due diligence obligations.
The Delegated Act also clarifies a number of categories that have caused operational uncertainty. Waste, used, and second-hand products are explicitly placed out of scope, including components of relevant products if they qualify as waste. Samples and products used for examination, analysis, or testing are excluded, recognising that subjecting low-value, often supplier-discovery items to full due diligence would be disproportionate. Packing materials and containers are out of scope when used to support, protect, or carry another product, including reusable packaging once it is in that role. Marketing and information materials accompanying another product or supplied free of charge are excluded, as are items of correspondence. The Commission has also clarified that bamboo, rattan, reeds, rushes, osier, raffia, treated cereal straw, and lime bark are not within the wood scope.
These changes are not yet final. The draft is open for public feedback until 1 June 2026, and operators with material exposure to any of the affected categories should consider whether to respond.
What the updated Guidance and FAQ clarify
The updated Guidance and the fifth iteration of the FAQ address five areas the Commission identified as needing further clarification, drawn from more than 750 questions and comments submitted by stakeholders following the December 2025 amendment.
The first concerns micro and small primary operators, the new category created for farmers and foresters in low-risk countries who place products from specific plots of land. The updated documents clarify how the size threshold is determined, how to handle year-on-year fluctuations, when a postal address can replace geolocation data, and what counts as a major change requiring an updated simplified declaration. Forestry cooperatives are confirmed as able to submit on behalf of their members.
The second concerns downstream operators. The Commission confirms that the obligation on first downstream actors to collect and keep due diligence statement reference numbers is passive rather than proactive. There is no requirement to verify the validity of those reference numbers, only to retain them and pass them on where required. The flexibility for a single entity to act in multiple roles (importer and producer, for example) is clarified, and the treatment of re-imports is set out more fully.
The third concerns due diligence and legality. The updated guidance is clearer that information collection on legality should be proportionate to risk, with detailed evidence required only for higher-risk supply chains. A repository of national legislation in producer countries is planned, alongside guidance on how to make use of certification and third-party verified schemes within due diligence work.
The fourth concerns the Information System. The Commission has updated the system to support the simplified declaration for micro and small primary operators, and a voluntary mechanism for grouping due diligence statement reference numbers has been introduced for operators handling large transaction volumes. The earlier API for machine-to-machine bulk submissions remains in place.
The fifth concerns specific product-scope questions left over from the December 2025 amendment, including the treatment of printed products following the removal of HS 49 (books and printed material) by the co-legislators.
What this package does not resolve
The package addresses the most pressing operational questions, but several open items remain.
The proposed product scope changes are not yet adopted. The Delegated Act needs to clear its public feedback period and complete the formal adoption process. Operators with exposure to leather, soluble coffee, oleochemicals, or retreaded tyres should plan against both possibilities until the act is final.
A zero-risk country category requested by some stakeholders has not been introduced. The Commission’s existing low-risk classification is retained, with the simplified due diligence pathway it offers, but no further category sits below it.
The trade facilitation tools mentioned in the report, including the legislation repositories for producer countries and the formal linkage of certification schemes to due diligence, are described as planned rather than delivered. Operators relying on third-party certification for legality assurance should not assume this work is complete.
Finally, while the Commission has decided not to propose further amendments to the basic legal text, this is a policy decision rather than a procedural one. Further iterations of the FAQ and additional implementing or delegated acts may still emerge as the application date approaches and enforcement experience accumulates.
What this means for your EUDR work
For most companies we work with, the practical implications come down to three things.
First, the entry into application date of 30 December 2026 is unchanged for the vast majority of in-scope companies, with most micro and small operators receiving a further six months until 30 June 2027. The simplification package is meaningful, but it is not a new delay. Compliance preparation should continue on the current timetable.
Second, the proposed product scope changes warrant a focused review by anyone with material exposure to leather, soluble coffee, palm oil derivatives, oleochemicals, retreaded tyres, or waste-derived flows. The Delegated Act does not yet have force of law, but its direction of travel is clear, and businesses should be ready to adjust their portfolio classification once it is adopted.
Third, the operating model for downstream actors is now firmly established. Companies whose obligations have shifted from active due diligence to passive collection of reference numbers should align internal processes, supplier communications, and Information System registration accordingly. The simplified mechanism is a meaningful reduction in administrative effort, but only if it is implemented properly.
How Jordisk can Help
Preparing for EUDR is a significant challenge for companies along the entire value chain of products in scope. Our team of experts have been working with companies across all sectors for three years. We understand the challenges business face in building a clear operating model for EUDR, engaging their suppliers and collecting all the relevant data.
We provide pragmatic support to companies to help them integrate EUDR into their operating model. Using our experience with over 100 companies, combined with our expert knowledge to help you build the approach which is right for your business. Get in touch today to discuss with one of the team.
