On July 13, 2026, the European Commission (“Commission”) adopted two new Regulations that will shape the implementation of the EU Deforestation Regulation (Regulation (EU) 2023/1115, “EUDR”). The EUDR will start applying to large and medium-sized operators and traders at the end of this year (i.e., December 30, 2026).

This post provides a high-level overview of the key changes under the two new Regulations, their timelines for formal adoption, and some practical considerations for companies preparing for compliance.

Background and Context for the Measures

By way of background, under the EUDR, economic operators may only place on the EU market, make available in the EU, or export from the EU the specific commodities and products listed in Annex I to the EUDR if three cumulative conditions are met. The products must be:

(i) deforestation free;
(ii) produced in accordance with the relevant legislation of the country of production; and
(iii) covered by a due diligence statement (“DDS”).  

The EUDR establishes a role-based allocation of obligations along the supply chain, varying by the nature of the product, the commercial activity performed, and each actor’s position in the supply chain. 

These new Regulations come after the Commission published a simplification package earlier this year (see press release here), delivering on the Commission’s commitment to the European Parliament and Council of the EU to conduct a simplification review of the EUDR by April 30, 2026 (following the December 2025 Amending Regulation of the EUDR). For more detail, see our blog post on the December 2025 EUDR simplification here.

The first new regulation the Commission has adopted is a Delegated Regulation, which updates and simplifies the list of relevant products covered by Annex I of the EUDR. The Delegated Regulation is now subject to a two-month scrutiny period by the European Parliament and the Council, which is extendable by another two months, and will only enter into force following its publication in the Official Journal of the EU.

The second Regulation is Commission Implementing Regulation (EU) 2026/1565, setting out the functioning of the EUDR Information System used to submit DDSs and simplified declarations under the EUDR. The Implementing Regulation entered into force on July 17, 2026, and is directly applicable in all EU Member States.

Delegated Regulation: Targeted Changes to Products in Scope of EUDR

The Delegated Regulation refines the scope of products subject to due diligence obligations under the EUDR. In particular, it introduces “limited and targeted fixes” to the Annex I list of in-scope products, exercising the Commission’s power to update the list of relevant CN (Combined Nomenclature) codes (i.e., the 8-digit EU system for classification of goods) set out in that Annex.

Key changes introduced in the Delegated Act include:

• Additions to scope as of December 2027: The Delegated Regulation adds several products to Annex I that will only become subject to the Regulation as of December 30, 2027, giving operators, competent authorities, and customs authorities time to prepare:
  • Frozen cattle tongues, added for coherence given that fresh cattle tongues were already in scope.
  • Soluble coffee (extracts, essences, and concentrates of coffee), closing a gap in the coffee sector where other forms of coffee beans (e.g., roasted or green) were already covered.
  • Additional palm oil oleochemical derivatives, including certain hydrogenated and inter-esterified palm and palm kernel oils, crude glycerol, fatty alcohols, and related fatty acid salts and esters that have been synthesized using palm oil, extending the oleochemicals product pallet already captured under the EUDR. However, crucially, these products are excluded from the EUDR scope where they are used to manufacture human or veterinary medicinal products.
  • Certain soap products (bars, cakes, and other moulded shapes for toilet use, and soap in other forms) that contain or are made using palm oil, a change the Commission justified on coherence and effectiveness grounds across the oleochemicals product range.

• Removals and narrowing: The Delegated Regulation removes or narrows several product categories, most with immediate effect.
  • Cattle hides, skins, and leather (i.e., raw or preserved hides and skins, tanned or crust hides and skins, and further-prepared leather) are deleted from Annex I. This was among the more contested changes, and the Commission has signaled that the issue will be revisited as part of the general review required under Article 34(2) by June 2030.
  • Vulcanised rubber articles and belts (conveyor and transmission belts, and other articles of vulcanised rubber) are removed given their low natural rubber content and correspondingly limited deforestation impact.
  • Aircraft and motor vehicle seats are carved out of the broad wood-seat category that previously captured them, replaced by a narrower list of wood-seat and wood-parts codes.
  • Soya beans for sowing are excluded from the soybean category, which is narrowed accordingly.
  • Retreaded tires are narrowed so that the due diligence obligation applies only to the new rubber tread applied during retreading, rather than to the retreaded tire as a whole.
  • Live cattle entries are consolidated into a single CN code, a simplification with no substantive change to the product’s scope.

• Clarifications and narrower legal boundaries: The Delegated Regulation also introduces clarifications intended to sharpen the boundaries of existing obligations. Several of these clarifications were already included in the Commission’s April 2026 FAQs, and are now formalized in the Delegated Regulation itself. These include exclusions for:
  • Samples and products used for analysis, examination, and testing;
  • Certain palm oil derivatives used in the manufacturing of medicinal products for human or veterinary use;
  • Waste (covering, among others, cocoa waste and additional palm oil derivatives used as biofuel feedstock) for products that qualify as waste under Article 3(1) of the EU Waste Framework Directive (i.e., any substance or object which the holder discards or intends to discard, or is required to discard);
  • “Packing materials and containers” (i.e., wood- and paper-based packaging otherwise listed in Annex I) when used exclusively to support, protect, or carry another product placed on the market. The exclusion turns on that ancillary, supportive use, so it covers both single-use and reusable packing (reusable containers, pallet pools). EUDR obligations will only apply when packaging is first placed on the market in its own right (e.g., empty paper bags, cardboard boxes, or new pallets sold as products);  
  • “Marketing and information materials” accompanying another product, or supplied for marketing or information purposes free of charge such as labels;
  • Items of correspondence, which serve a communication purpose rather than a market purpose; and
  • Commodity- and species-origin clarifications: The Delegated Regulation inserts “ex” before various oil palm and rubber entries to confirm they are covered only where the product is actually produced using a relevant commodity (for example, tires made with natural rather than synthetic rubber). Relatedly, it confirms that wood-sector products made of bamboo, rattan, or other non-wood woody materials – including reeds, rushes, osier, raffia, cleaned, bleached or dyed cereal straw, and lime bark – do not fall within scope, as these are not the “wood” commodity within the meaning of the EUDR.

Overall, the revised Annex I draws finer distinctions between products, so whether an item is in scope increasingly turns on its specific 8-digit CN code rather than on the broader product category it sits in. Additionally, in some cases, scope no longer turns on the product’s classification alone: several of the new carve-outs depend instead on how an item is used or supplied, so that an otherwise-covered product – such as packaging, a sample, or accompanying marketing material – may fall outside the Regulation by reason of its function or the purpose for which it is placed on the market. In practice, companies will need to check the precise CN code of each product and, where a carve-out may apply, how it is used or supplied to confirm whether it falls within the EUDR’s scope.

Implementing Regulation on the EUDR Information System

The Commission has also adopted the Implementing Regulation establishing technical rules for the EUDR Information System, pursuant to Article 33(3) of the EUDR. The EUDR Information System is the platform through which EUDR DDSs and simplified declarations are submitted. The Implementing Regulation entered into force on July 17, 2026, and is directly applicable in all EU Member States.

This Regulation updates Implementing Regulation (EU) 2024/3084 to operationalize the new “downstream operator” and “micro or small primary operator” categories introduced by the December 2025 Amending Regulation, which relieved downstream operators and traders of the obligation to submit DDSs and allowed micro and small primary operators to submit a simplified declaration instead of a full DDS.

The Regulation introduces several practical improvements, including:

• A Simplified Declaration form for micro and small primary operators: Users may submit a Simplified Declaration directly, or, where the required information is already held in a Member State or EU database, Member States may feed that information directly into the Information System on behalf of the operator.

• A voluntary grouping feature: Users may group multiple previously submitted DDSs or simplified declarations into a single grouped statement by referencing their prior reference numbers or declaration identifiers (for example, to cover a master DDS spanning multiple shipments).

• Streamlined user registration: Users must register once and may hold multiple roles under a single account in the Information System.

Additional functionalities are expected to be introduced later this summer, and the Commission is separately working with Member States to feed information from national databases directly into the Information System to further reduce the burden on micro and small primary operators.

Taken together, these targeted additions, removals, and clarifications, alongside the platform improvements, are intended to give operators, customs authorities, and competent authorities greater clarity and legal certainty on what falls within scope and what compliance will require ahead of the EUDR’s December 2026 application. With no further postponement planned, companies should consider revisions that may need to be made to compliance programs ahead of this date.

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If you have any questions concerning the material discussed in this post or on the EUDR in general, please contact the members of our team.