Insights
Second Update on the EU Deforestation Regulation (EUDR)
Aug 21, 2026On 13 July 2026, the European Commission adopted two measures finalising its simplification package for the EU Deforestation Regulation (EUDR): a Delegated Act amending the regulation's product scope and an Implementing Act establishing the technical specifications for the EUDR Information System. These measures build upon the legislative amendment agreed by the European Parliament and the Council in December 2025 and complete the simplification package presented by the Commission in May 2026 (see our previous article).
Background
The EU Deforestation Regulation aims to ensure that key goods placed on the EU market do not contribute to deforestation and forest degradation, both within the EU and globally. The regulation covers the following seven commodities: cattle, wood, cocoa, soy, palm oil, coffee, and rubber, alongside some of their derived products.
Under the Regulation, any operator or trader who either places these commodities on the EU market or exports from it, must be able to prove that the products do not originate from recently deforested land and have not contributed to forest degradation. Strict penalties apply in cases of non-compliance.
The products within scope are limited to those listed in Annex I to the regulation. All industries are potentially covered as the regulation is sector-agnostic. Obligations will fall on a variety of companies, including ones located outside of the EU (e.g. for distance sales).
The Regulation will apply from 30 December 2026 for large and medium companies, as well as for micro and small enterprises from the timber sector. It will apply from 30 June 2027 for other micro and small enterprises.
July 2026 Update
The measures adopted on 13 July include:
Delegated Act on product scope
The Delegated Act incorporates targeted amendments to the EUDR product scope. Unfortunately, the Act does not contain a consolidated prospective update of how Annex I would read if and when the proposal comes into force.
Several product categories are removed from scope, including cattle hides, skins and leather, re-treaded tyres, soybeans for sowing, articles of vulcanised rubber, conveyor and transmission belts, and aircraft and motor vehicle seats.
Conversely, soluble coffee, certain palm oil derivatives, and frozen cattle tongues now fall within scope; however, these products will not become subject to the Regulation until 30 December 2027.
It should be noted that these changes concern derived products only - the list of seven core commodities remains unchanged. The Delegated Act also introduces certain exemptions such as product samples, certain packing materials, used and second-hand products, and waste, as well as products used in the manufacture of medicinal products.
The Act will be transmitted to the European Parliament and the Council for scrutiny before entering into force.
Implementing Act on the Information System
The Implementing Act establishes updated technical rules for the EUDR Information System (i.e. the platform through which operators submit their due diligence statements and, where applicable, simplified declarations). The Commission is updating the Information System to reflect the changes introduced by the revised Regulation and to enhance its user-friendliness. Key improvements include a simplified declaration process for micro and small primary operators and updated API specifications for automated data exchange.
The System reopened at the end of June 2026 following a period of technical upgrades. Training sessions for businesses are planned from the end of July, with further functionalities to be introduced later in the summer.
- Updated Guidance Document and FAQs
The measures adopted in this July package complete the simplification one presented by the Commission in May 2026, which also included an updated Guidance Document and Frequently Asked Questions. Both remain unchanged since their initial publication in May 2026, with the Guidance Document now formally adopted in its final version. These also address the topics most frequently raised by stakeholders, providing further clarification of obligations for the downstream supply chain and the simplified regime applicable to micro and small primary operators. The Guidance, previously available only in English, has now been formally adopted in all EU official languages.
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