EUDR – What changes in 2026 and what remains the same for forest owners and forest managers

In December 2025, the European Union adopted an amendment to the EUDR (EU Deforestation Regulation) — Regulation (EU) 2025/2650 — with the objective of ensuring that only products which:

a) do not cause deforestation;
b) have been produced in compliance with the relevant legislation of the country of production; and
c) are accompanied by a due diligence statement,

may be placed on the EU market.

The 2025 amendment does not change this objective. Instead, it simplifies the rules, clarifies the distribution of obligations among different actors in the supply chain, and reduces the technical burden on the EU Information System.

Entry into force of the amended EUDR (wood material commodity)

• 30 December 2026 – Entry into force of the amendment for all types of operators.

Known categories among forest owners and forest managers:

• Operators – entities placing relevant products on the EU market for the first time.

New categories of operators after the amendment (context of the Slovak Republic)

Primary operators

Who are they?
Entities that first produce or import a relevant product and place it on the EU market.
Examples: All forest owners and forest managers, importers from third countries (EU importers), regardless of size.

Obligations:

Primary operators must:

• carry out due diligence (DDS),
• demonstrate that products are deforestation‑free and legally produced,
• submit a due diligence statement to the EU Information System, including geolocation data,
• retain all documentation for at least 5 years,
• provide the DDS reference number (or identifier) to subsequent operators in the supply chain.

Forest owners and forest managers are further divided into:

Micro and small primary operators

Who are they?
Natural persons, forest owners and forest managers in low‑risk countries.
According to Directive 2013/34/EU:

Obligations:

• They do not submit repeated DDS.
• They submit a one‑off simplified statement, after which they receive a one‑off identifier that accompanies all their deliveries.
• The statement is linked to the geolocation of all plots they own or manage.

Additionally, under Article 4a(4):

“Where all information listed in Annex III is available in a system or database established under Union or national law, other than the Information System referred to in Article 33, micro and small primary operators shall not be required to submit the one‑off simplified statement referred to in paragraph 2. Member States shall make such information available in the Information System referred to in Article 33. A micro or small primary operator may place relevant products on the Union market or export them only after an identification code has been assigned to the statement.”

Medium and large primary operators

These are all primary operators that do not fall under the “micro and small” category.

Relevant provision:

“Operators who, on the basis of due diligence carried out in accordance with Article 8, conclude that the relevant products comply with Article 3 before placing them on the market or exporting them, shall submit a due diligence statement via the Information System referred to in Article 33. The electronically accessible and transferable due diligence statement must contain the information set out in Annex II and a declaration by the operator that due diligence was carried out and that no risk or only negligible risk was identified.”

Summary in plain language

From 30 December 2026, all Slovak forest owners and forest managers will place wood material on the market using the EU Information System.

Micro and small operators

(Natural persons and small forest owners/managers with turnover ≤ €10 million, < 10 employees, and assets ≤ €5 million):

• Must carry out due diligence and maintain a due diligence system in accordance with Act 81/2025 Coll.
• Submit a one‑off simplified due diligence statement, including geolocation of all plots.
• Receive a one‑off identifier, similar to a reference number.
• This identifier accompanies every placement of wood on the market, without time limitation, unless significant changes occur (e.g., changes in land ownership or area).
• May authorise another downstream operator or trader (not a natural person or micro‑enterprise) to act as their authorised representative.
• Under Article 4a(4), they may effectively wait for the one‑off identifier to be issued by a state‑designated body if a national database already contains Annex III information (in Slovakia: the ISLHP database managed by NLC).

Other forest owners and forest managers (medium and large)

They place wood material on the market using a due diligence statement submitted to the EU Information System, with a standard reference number linked to the geolocation of the plots of origin.

All primary operators in Slovakia retain full responsibility for ensuring that wood placed on the market complies with Article 3:

a) it does not cause deforestation;
b) it has been produced in compliance with the relevant legislation of the country of production;
c) it is accompanied by a due diligence statement.