EUDR: Simplification-Review, new guidance documents and amendment of Annex I

Today, 4 May 2025, the Commission has published the long-awaited ‘Simplification-Report’ on the EU Deforestation Regulation (EU) 2023/1115 (EUDR). The report and links to all accompanying documents can be found in the Commission’s official press release (available: here).

In addition to the report, the Commission has also published a comprehensive package of new documents and planned measures. However, the following point is particularly worth highlighting:

There are no plans to amend the main text of the EUDR again.

It can therefore be assumed that the EUDR, in its current form, will apply from 30 December 2026. The only exceptions to this are minor amendments to the product scope and to the Implementing Regulation on the EUDR information system. Economic operators are therefore advised to start preparing for the implementation of the EUDR.

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The contents of the press release in detail:

What new documents and measures has the Commission published or announced?

In addition to the ‘Simplification-report’, the Commission has published two updated interpretative documents and a draft Delegated Regulation amending Annex I to the EUDR.

The updated guidance documents are as follows:

• An updated version of the EUDR FAQ
• A revised version of the EUDR Guidelines

Both documents are intended to clarify questions of interpretation relating to the EUDR, but are not legally binding.

In addition, the Commission has presented or announced the following measures:

• Introduction of a new Delegated Regulation amending Annex I to the EUDR
• Announcement of an amendment to the Implementing Regulation on the EUDR Information System

What do the new EUDR FAQs and guidelines say?

Both the FAQs and the guidelines now take into account the EUDR as amended in December 2025. They provide explanations regarding the addressees and their revised obligations under the EUDR. Among other things, the following aspects are covered:

• Explanations regarding the due diligence obligations
• Requirements for associations or producer groups wishing to issue due diligence statements on behalf of their members
• Classification of businesses as micro- or small enterprises
• Comprehensive examples of the obligations of various economic operators along the supply chain

To what extent does the Commission propose an amendment of Annex I of the EUDR?

Annex I specifies the ‘relevant products’ to which the EUDR applies. If a product does not fall under one of the HS codes under the Combined Nomenclature listed in Annex I, the EUDR does not apply to that product. The Commission has now presented a proposal for a new Delegated Regulation amending Annex I. The proposed amendment not only removes products from the scope of the EUDR but also adds new products in some cases. The amendment has not yet been adopted, so no definitive statements can be made regarding its final content. Comments on the proposed regulation may be submitted until 1 June 2026.

Among other things, the following products are to be excluded from the scope of the EUDR:

• Leather
• Retreaded tyres
• Waste and second-hand goods
• Products for testing
• Packaging that is in use or has already been used
• Marketing and information materials

The EUDR is to apply to the following products in future:

• Soluble coffee
• Certain palm oil products

What developments should companies affected by the EUDR keep an eye on?

It is expected that Annex I to the EUDR will be finalised after 1 June 2026. No further amendments to the text of the EUDR are anticipated thereafter.

The following deadlines should also be noted:

30 December 2026: Date of application of the EUDR

From 30 December 2026, the EUDR will apply to market participants that are medium-sized and large enterprises. It will also apply to small and micro-enterprises that deal in products as listed in Annex I to the EU Timber Regulation (EU) No 995/2010 (EUTR) (Article 38(2), (3) EUDR).

30 June 2027: Date of applicability for small and micro-enterprises

From 30 June 2027, the EUDR will apply to small and micro-sized enterprises. Enterprises trading in products as defined in Annex I to the EU Timber Regulation are exempt from this later date of application (Article 38(3) of the EUDR).