The Commission is working on specifying the EUDR provisions - possible expansion of the product list
According to the amendment to the EUDR regulation published on 23 December 2025, the obligation to apply the EUDR provisions has been postponed by 12 months. The new requirements will apply from 30 December 2026 for large and medium‑sized enterprises, and from 30 June 2027 for micro and small enterprises [1]. At the same time, the Commission has been obliged to review the EUDR provisions with a view to introducing further simplifications. As agreed last year, the Commission is expected to present a report by the end of April. Nevertheless, it is worth preparing the organization for the new obligations now, as no changes are expected to the core wording of the EUDR regulation.
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Changes to the list of products?
It is important to recall that the EUDR provisions apply to a group of seven commodities - coffee, cocoa, palm oil, cattle, soy, wood and rubber - as well as selected derived products. EUDR prohibits placing on the market, making available on the market, or exporting from the EU any products or commodities covered by the EUDR regulation unless they:
- are deforestation-free,
- have been produced in accordance with the relevant legislation of the country of production, and they are covered by a due diligence statement or a simplified declaration.
At last week’s meeting with industry and non‑profit organizations representatives, the European Commission assured that the core text of the EUDR regulation, which is set to apply from December 2026, will not be amended.
The Commission is expected to present a simplification package by the end of April 2026, as agreed last year. This package will also include a delegated act amending the EUDR regulation annex that defines which products are covered by the regulation.
Among the changes under consideration is the possible extension of the product list to include soap made from palm oil and instant coffee - products that are currently not covered by EUDR.
The Commission also confirmed that:
- the benchmarking system classifying countries according to deforestation risk - from low to high - will not be reviewed this year. The update will be postponed until the regulation enters into force.
- additional technical updates are planned, including provisions relating to the information system, which is intended to reflect the simplified requirements for smallholders agreed in December last year.
- further guidance will be published to clarify the application of the EUDR provisions to e‑commerce and re‑imports, as well as due diligence obligations for downstream operators and traders.
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The EUDR regulation introduces rules that significantly impact business operations, including supply chain control processes. Comprehensive preparation will facilitate successful compliance with the regulation. If you need support in determining your organization’s obligations, providing substantive training for teams, or assessing how the EUDR provisions will affect your business, please contact our specialists directly.
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