EU Clarifies Implementation of Deforestation Regulation

Since entering into force in 2023, the European Union Deforestation Regulation (EUDR) has faced several challenges and proposed revisions, all of which have made it difficult for organizations to understand their responsibilities in ensuring products impacted by deforestation don't enter the EU market.

Now, the EU is another step closer to finalizing the implementation of the EUDR, which will apply from December 30, 2026, for large and medium operators and from June 30, 2027, for small and micro operators.

The EUDR impacts seven commodities and derived products associated with deforestation: cattle, cocoa, coffee, palm oil, rubber, soy, and wood. Organizations placing products derived from these commodities on the EU market must be able to demonstrate in a due diligence statement that they are free from deforestation or forest degradation that occurred after December 31, 2020, and that they were produced in accordance with the laws of the country of production, including human rights laws and the rights of Indigenous Peoples.

The measures adopted on July 13, 2026, include a delegated act, revising the list of products covered under the EUDR, and an implementing act, with details of the information system for submitting due diligence statements and declarations.

Jessika Roswall, European commissioner for environment, water resilience, and a competitive circular economy, said in a press release that the measures will contribute to a smooth and effective implementation of the regulation.

“With this package, we are providing the clarity and predictability that businesses, member states, and our international partners need to prepare for the application of the EU Deforestation Regulation at the end of 2026,” said Roswall.

Changes to Product Scope

The delegated act revises the scope of products derived from commodities, not the commodities themselves. It incorporates the information collected during the public feedback period from April 15 to May 13, 2025.

The act removes cattle hides, skins, leather, re-treaded tires, soybeans for sowing, vulcanized rubber, conveyor and transmission belts, and seats for aircraft and motor vehicles from the scope of the EUDR, while adding soluble coffee, some palm oil derivatives, and frozen cattle tongues. These changes were assessed in accordance with the staff working document published on May 4, 2026. New products added to the scope will be subject to the regulation from December 30, 2027, to allow businesses time to prepare.

The act also clarifies exemptions for products used for analysis, examination, and testing and for categories such as waste, used, and second-hand products; packing materials; and materials used in the development of medicinal products.

Rules for EUDR Information System

The EUDR Information System is the means by which producers will submit due diligence statements to demonstrate their compliance with the EUDR. It includes rules for the protection of personal data, exchanging data with other IT systems, and contingencies for system unavailability.

After a series of technical updates, the system has re-opened and will receive updates and improvements over time, with regular updates to documentation and training sessions beginning at the end of July 2026.

The act establishes the technical rules for the system and introduces simplified declarations for micro and small operators, as well as updated technical specifications for automated application programming interfaces (APIs).

Simplifications Don't Mean It's Simple

Since the publication of the Draghi Report on September 9, 2024, the EU has rapidly pursued simplification of its existing sustainability regulations. As part of that process, the EUDR has gone through several rounds of revisions and delays.

However, 3E Materials and Sustainability Regulatory Manager Cassidy Spencer said that while these latest revisions might provide clarity for companies, that doesn't necessarily make compliance easy.

“What stands out here is that companies can't treat scope clarification as a one-time legal update,” said Spencer. “Every adjustment to the product list has downstream effects on supplier questionnaires, ERP classifications, due diligence workflows, and evidence retention. The risk is not only whether a product is technically in or out of scope, but whether the business can consistently prove how that determination was made.”

Spencer said that for many organizations, the next practical step will be to revisit their product mapping logic, document the rationale behind inclusion and exclusion decisions, and make sure procurement, compliance, and IT teams are working from the same interpretation before due diligence submissions begin.