EUDR: obligations for exporters from December 2026

Update, 1 October 2026

Since first publication, the Commission's EUDR page, read on 1 October 2026, cites the Annex I Delegated Regulation (EU) 2026/2102 by number and gives 30 December 2027 as the date from which the added products become subject to the EUDR. It still gives 30 December 2026 and 30 June 2027 as the main application dates. We could not read the Official Journal text (EUR-Lex returned an empty response), so we have not confirmed when the regulation was published or when its removals take effect. The draft sent to the Council provided for entry into force on the day after Official Journal publication, and secondary reports give 17 September 2026 for publication and 18 September for entry into force, but those reports are not confirmed by a primary source we could read. Check the Official Journal text before relying on the removals. We did not re-check the country-risk list or the Information System Implementing Act for this update.

The dates that matter, read directly from Article 38

We pulled the EUDR's own consolidated legal text rather than relying on secondary summaries. Article 38(2): large and medium operators (and, per 38(3), micro/small operators who already handled EU Timber Regulation-covered wood products as of 31 December 2024) must comply from 30 December 2026. Article 38(3)'s carve-out applies to everyone else — other micro and small enterprises, established as such by 31 December 2024 — who get until 30 June 2027. The carve-out is an exception to the deferral, not to the Regulation: if your micro or small business already handled EUTR wood products, you don't get the later date.

We also checked whether the underlying country-risk list is still current. Implementing Regulation (EU) 2025/1093, which classifies every country as low, standard or high deforestation risk, was in force, unamended and not repealed when we last checked it on 5 August 2026; we did not re-check it on 1 October. 140 countries are classified low-risk; 4 (Belarus, North Korea, Myanmar, Russia) are high-risk; everyone else defaults to standard risk.

The Parliament resolution: what it actually did, and didn't do

On 9 July 2025 the European Parliament adopted a non-legislative resolution (373 votes to 289) calling on the Commission to repeal the country-risk benchmarking regulation, arguing it exceeded the Commission's implementing powers. Trade coverage often reports this as the list being 'rejected' — that's a mischaracterisation.

The resolution was adopted under Article 11 of Regulation 182/2011, which lets Parliament 'indicate' a view that a draft implementing act exceeds its powers — it carries no power to annul, veto or suspend. The Commission's formal reply (27 October 2025) states plainly that it considers the regulation within its powers and intends to uphold it, noting the resolution was tabled after the act had already entered into force. The list has been in force, unchanged by this resolution, since.

The Commission has said a first review of the country classifications is envisaged during 2026, using newly published FAO Global Forest Resources Assessment 2025 data. As of our last check on 5 August 2026, no revised list had been published and the May 2025 classification (2025/1093) was the operative one; we have not re-checked this since.

Two changes to the Annex I product scope

Annex I has moved twice since 2023. Regulation (EU) 2025/2650 removed printed books, newspapers, pictures and related printed-industry products from EUDR scope entirely. If your only Annex I exposure was through printed paper products, that line is no longer a due-diligence obligation.

The second change is Commission Delegated Regulation (EU) 2026/2102, adopted on 13 July 2026; we could not confirm from a primary source the date from which its removals take effect. It removes cattle hides, skins and leather, re-treaded tyres, soybeans for sowing, articles of vulcanised rubber, conveyor and transmission belts, and aircraft/motor-vehicle seats from Annex I, while adding soluble coffee, certain palm oil derivatives and frozen cattle tongues. The Commission states that the added products become subject to the Regulation from 30 December 2027, and the Commission's transmittal text gives the reason as time for operators and authorities to adapt to the new categories. The same day, the Commission also adopted an Implementing Act setting the technical rules for the EUDR Information System; we have not re-checked its status.

We covered both acts in more detail when they were adopted. An earlier version of this alert wrongly treated the product-scope act as fabricated; that was corrected on 2026-08-24.

A real simplification worth knowing: the due diligence chain got shorter

Regulation (EU) 2025/2650 collapsed who actually submits a due diligence statement: only the first operator placing the product on the EU market, or exporting it, files a DDS. Downstream operators and traders no longer file their own DDS or re-verify upstream diligence — they register in the Information System and passively hold the reference number that was already generated upstream. If you sell through an EU distributor rather than placing goods on the market yourself, this materially changes what your downstream counterparty needs from you.

A further simplification applies specifically to micro and small primary producers established in a country classified low-risk: a one-time simplified declaration instead of a full DDS, and a postal address or cadastral reference can substitute for geolocation coordinates. This gate matters for Latin American exporters in particular — Costa Rica, Chile and Uruguay are classified low-risk, while Brazil, Colombia, Peru, Ecuador, Honduras, Mexico, Argentina and Paraguay are standard-risk and don't qualify for this route regardless of operator size.

What this means if you don't ship into the EU today

If none of your product lines carry an Annex I HS code, none of this applies — check your exact code against Annex I rather than assuming a whole HS chapter is in or out, since several entries carry an 'ex' prefix covering only part of a heading.

If you do ship EU-bound cattle, coffee or cocoa, the geolocation and due diligence statement (DDS) mechanics are unchanged by anything in this alert. See our EUDR guide for the compliance path itself.