EUDR changes in 2026 for processors, manufacturers and traders

Following the amendment of the EUDR (2025/2650) and according to the latest interpretation issued by the European Commission (UNEP‑WCMC, 2025), clear rules apply to processors, manufacturers and traders (downstream operators). The key change is that obligations differ depending on the size of the enterprise, which is the basis for reducing the regulatory burden under the EUDR for smaller domestic (EU‑based) processors and traders.

Basic definitions in the processing chain

“Operator” means any natural or legal person who, in the course of a commercial activity, places relevant products on the market or exports them, with the exception of operators at the lower level of the supply chain.

“Primary micro‑operator or small primary operator” means an operator who is a natural person, a micro‑enterprise or a small enterprise within the meaning of Article 3(1) and Article 3(2), first subparagraph, of Directive 2013/34/EU, regardless of its legal form, established in a country classified as low‑risk in accordance with Article 29 of this Regulation, and who, in the course of a commercial activity, places on the market or exports relevant products that the operator has grown, harvested, obtained or raised on the relevant plots of land, or, in the case of cattle, in facilities located in that country.
This category also includes operators who exceed at least two of the three criteria set out in Article 3(1) and Article 3(2), first subparagraph, of Directive 2013/34/EU, but who can demonstrate that the parts of their total balance sheet, net turnover and average number of employees relating to the relevant commodities and relevant products do not exceed at least two of the three criteria.

“Downstream operator” means any natural or legal person who, in the course of a commercial activity, places on the market or exports relevant products manufactured using relevant products, provided that all such products are covered by a due diligence statement or a simplified statement.

“Trader” means any person in the supply chain other than an operator or downstream operator who makes relevant products available on the market in the course of a commercial activity.

Key provisions of the amendment

Objective of the amendment

To ensure that products placed on the EU market:

(a) do not cause deforestation,
(b) are produced in compliance with the legislation of the country of production,
(c) are accompanied by a due diligence statement.

Entry into force

• 30 December 2026 – applies to all types of operators, including processors of the commodity wood material.
• 30 June 2027 – applies to other commodities for micro, small and medium‑sized enterprises (SMEs).

Categories of operators by size

Micro, small and medium‑sized enterprises (SMEs)

Entities that process, manufacture or sell relevant products and meet SME criteria.

Large processors and traders (non‑SMEs)

All entities that do not meet the SME criteria.

Distinction between upper‑chain and lower‑chain actors

The revised regulation distinguishes between:

• “Operators in the upper part of the supply chain”, responsible for carrying out due diligence before first placing relevant products on the EU market or exporting them, and
• “Operators and traders in the lower part of the supply chain”, who do not carry out due diligence.

Upper‑chain operators (operators)

These include:

• Importers placing relevant products on the EU market under the customs regime “release for free circulation”;
• Domestic manufacturers placing relevant products (as listed in the EUDR Annex – selected tariff codes) on the EU market for the first time;
• Exporters exporting relevant products under the customs regime “export” that are not yet covered by a DDS or simplified customs declaration.

Obligations of upper‑chain operators

Before placing relevant products on the EU market or exporting them, operators must:

• carry out due diligence (Article 4(1));
• submit the DDS to the Information System before placing the products on the EU market or exporting them.

They are responsible for ensuring compliance with Article 3, including:

• ensuring that products are deforestation‑free,
• ensuring that products are produced in accordance with the relevant legislation of the country of production.

Operators must also:

• retain records of due diligence statements for five years from the date of submission;
• provide downstream operators and traders with the DDS reference numbers (Article 4(7));
• notify competent authorities of any new relevant information, including substantiated concerns indicating risk of non‑compliance, and inform traders to whom they supplied the products (Article 4(5)).

Downstream operators and traders

Downstream operators and traders:

• are not required to carry out due diligence,
• are not required to submit DDS,
• have significantly reduced information obligations.

Important:First downstream operator/trader

The first downstream operator or trader (regardless of SME or non‑SME status) must:

• collect and retain certain information on relevant products they intend to place on the market, make available, or export;
• this includes DDS reference numbers or identifiers received from upper‑chain operators (Article 5(3)(a)).

Traceability obligations

Due to their role in ensuring deforestation‑free supply chains:

• non‑SME downstream operators and traders must register in the Information System before placing, making available, or exporting relevant products (Article 5(2)).

All downstream operators and traders must:

• collect and retain basic information on relevant products, including supplier and customer data;
• notify competent authorities if they obtain information indicating risk of non‑compliance (Article 5(5)).

In case of substantiated concerns, non‑SME downstream operators and traders must:

• verify that due diligence was carried out and that no or only negligible risk was identified;
• otherwise, they may not place, make available, or export the product (Article 5(6)).

Customs declarations – importers and exporters

An operator placing imported products on the EU market or exporting relevant products must include in the customs declaration:

• the DDS reference number, or
• the identifier of the due diligence statement.

The same DDS reference number may be used for multiple customs declarations if all EUDR requirements are met.

Authorised representatives

An operator may appoint an authorised representative to submit DDS or simplified statements on its behalf (Article 6(1)).

Summary

DDS is submitted only by upper‑chain operators, i.e.:

• growers, farms, forest owners,
• importers from non‑EU countries with unspecified or high risk.

Downstream operators and traders

If SME:

• no registration in the Information System,
• no DDS submission,
• no legal responsibility for correctness of DDS information received.

If non‑SME:

• registration required,
• no DDS submission,
• no legal responsibility for correctness of DDS information received,
• must verify due diligence in case of substantiated concerns.

All first downstream operators/traders must:

• collect and retain information on suppliers and customers (business name, address, country of origin, DDS reference numbers/identifiers),
• provide this information to their buyers.