EUDR is Regulation (EU) 2023/1115, which bans placing certain commodities on the EU market unless they are deforestation-free and covered by a due diligence statement. It has been amended twice, both times in the week before Christmas, which is part of why the record is so muddled.
Three corrections do most of the work.
“The grace period ends 30 June 2026 for small businesses.”
That was the micro and small operator date under the first postponement, Regulation (EU) 2024/3234. The second postponement replaced it. The date is now 30 June 2027.
“Small companies get an extra six months.”
Only if four conditions are met at once, including one — being established by 31 December 2024 — that has nothing to do with size and is rarely mentioned.
“Paper and printed products are in scope.”
Printed matter of Chapter 49 — books, art prints, posters — was deleted from Annex I in December 2025. Pulp and paper of Chapters 47 and 48 stayed.
The two dates, from the article that sets them
Regulation (EU) 2025/2650 of 19 December 2025 replaced Article 38 of the EUDR outright. This is the replacement text, and it is the only place the dates come from.
“2. Subject to paragraph 3 of this Article, Articles 3 to 13, Articles 16 to 24 and Articles 26, 31 and 32 shall apply from 30 December 2026.
3. Except as regards the products covered by the Annex to Regulation (EU) No 995/2010, for operators, whether natural persons or micro- or small undertakings … irrespective of their legal form, who were established as such by 31 December 2024, the Articles referred to in paragraph 2 of this Article shall apply from 30 June 2027.”
Regulation (EU) 2023/1115, Article 38(2)–(3), as replaced by Regulation (EU) 2025/2650, Article 1(25)So 30 December 2026 is the date. 30 June 2027 is an exception carved out of it, and paragraph 3 is the whole of that exception — there is no other extension anywhere in the regulation.
The later date is four conditions, not one
Every clause in paragraph 3 is load-bearing, and they are cumulative. Fail one and your date is 30 December 2026.
You are an operator
Paragraph 3 says “for operators”. It does not say downstream operators, and it does not say traders. Those are separate defined categories with their own obligations, and neither is given the later date.
Miss this if: you buy finished goods that are already covered by someone else's due diligence statement. You are probably not an operator at all — see the next section.
You are a natural person, or a micro or small undertaking
Measured against Article 3(1) and Article 3(2) of Directive 2013/34/EU. On the thresholds as uprated in 2023, micro means not exceeding two of: €450,000 balance sheet total, €900,000 net turnover, 10 employees. Small means not exceeding two of: €5m, €10m, 50 employees. Nearly every independent seller is inside this.
Miss this if: you are medium-sized. Medium is not included, despite “SME” being used loosely elsewhere in the same regulation for a different purpose.
You were established as such by 31 December 2024
The condition nobody quotes. It is a fixed historical cut-off, not a rolling one, and the first postponement used 31 December 2020 — so it has already moved once and is easy to misremember.
Miss this if: you registered the business in 2025 or 2026. A new small business gets no extension at all. It is on the 30 December 2026 date alongside large operators.
Your products are not on the old timber list
The exception does not apply “as regards the products covered by the Annex to Regulation (EU) No 995/2010” — the annex to the old EU Timber Regulation. Those products were already regulated, so they get no further grace.
Miss this if: you sell wood or timber products that were within EUTR. For those lines your date is 30 December 2026 even if you satisfy the other three conditions.
Worth noting alongside: the EUTR itself is repealed with effect from 30 December 2026, but it continues to apply until 31 December 2029 to timber produced before 29 June 2023 and placed on the market from 30 December 2026. Old stock does not simply fall out of regulation; it changes which regulation it falls under.
What left the scope list in December
The same amending regulation deleted one line from Annex I, and for anyone selling printed products it is the most consequential thing in the whole amendment:
“in Annex I, in the table, the line ‘ex 49 Printed books, newspapers, pictures and other products of the printing industry, manuscripts, typescripts and plans, of paper’ is deleted”
Regulation (EU) 2025/2650, Article 1(26)Chapter 49 of the customs nomenclature is printed matter. Chapter 48 is paper and paperboard and articles made from them. Only Chapter 49 went. That produces a line that looks arbitrary until you see where it is drawn, and it runs straight through a lot of small-seller catalogues.
| If you sell | Annex I position after December 2025 |
|---|---|
| Art prints, posters, printed books, greeting cards, printed planners | Chapter 49 — removed from Annex I |
| Blank notebooks, paper stock, cartons, paper packaging | Chapters 47–48 — still listed, except bamboo-based and recovered (waste and scrap) products |
| Wooden homeware, boards, small wooden goods | Listed at 4421, “other articles of wood” |
| Wooden seating and furniture | Listed at ex 9401 and at 9403 30, 40, 50, 60 and 91 |
| Cattle leather, hides | Listed at ex 4101, ex 4104 and ex 4107 |
| Finished leather goods — bags, wallets, belts | Chapter 42 is not listed in Annex I |
| Rubber goods, including rubber apparel and accessories | Listed across 4001 to 4017, including ex 4015 and ex 4016 |
Two of these are worth saying out loud because they invert the common assumption. A printed art poster is out; the blank paper it was printed on would have been in. And a cattle-leather wallet is not in Annex I as a finished article, although the leather itself is at an earlier point in the chain. The regulation attaches to commodities and to specific product codes, not to the idea of a material.
Three boxes, and most sellers are not in the first one
The December amendment created a new category specifically to take small downstream businesses out of the reporting system. Which box you are in decides everything you have to do.
| Operator | Downstream operator | Trader | |
|---|---|---|---|
| Who this is | Places a relevant product on the EU market for the first time, or exports it | Places on the market products made using relevant products, all of which are already covered by a due diligence statement or simplified declaration | Anyone else in the chain who makes relevant products available on the market |
| Typical seller case | You import wooden or leather goods from outside the EU yourself | You make goods in the EU from EU-bought materials that arrived with a statement | You resell finished relevant products within the EU |
| Due diligence statement | Yes — this duty is yours alone | No | No |
| Register in the information system | Yes | Only if you are not an SME | Only if you are not an SME |
| Collect reference numbers | n/a — you generate them | Only where your own supplier is an operator | |
| Keep records | Yes | Supplier and customer details, five years | |
The two “only” rows are the simplification, and they are worth reading carefully because they are more generous than most summaries suggest.
Registration. Article 5(2) requires registration in the information system only from downstream operators and traders that are not SMEs. SME here includes medium-sized undertakings, so the threshold for having to register is large — broadly, exceeding two of €25m balance sheet, €50m turnover and 250 employees. An independent seller reselling within the EU does not register.
Reference numbers. Article 5(3)(a) requires you to record your supplier's details, and the due diligence statement reference numbers “only in the event that their supplier is an operator”. The recital explains the design: the obligation is meant to fall on the first downstream operator or trader in the chain and not on everyone below them. If you buy from a distributor who is themselves a downstream operator, you keep their details and no reference numbers.
Not your size. It is whether anything you sell enters the EU market for the first time through you. If you import wooden homeware or leather from outside the EU and sell it to EU buyers, you are an operator, you file due diligence statements with geolocation data for the plots of land, and no smallness relieves you of that — the only thing your size changes is the date. If everything you sell was already on the EU market when you bought it, you are downstream, and the December amendment has removed most of what you would otherwise have filed.
Unsettled as of 5 August 2026
Whether a third postponement arrives. Two have happened, both in December, both late. Article 34 as amended also required the Commission to carry out a simplification review and report by 30 April 2026. We could not confirm the outcome of that report, and it is the most likely origin of any further change. Plan on 30 December 2026 and treat a further delay as a windfall.
Which country risk classifications apply. The amendment introduces “micro or small primary operators” — natural persons or micro and small enterprises established in a country classified as low risk, selling what they themselves grew, harvested or raised — and exempts them from filing a due diligence statement. That relief depends entirely on the country classification under Article 29, which we have not verified in its current form here.
How the codes get applied in practice. Annex I works on customs codes, and the Chapter 48 versus Chapter 49 boundary will decide real cases. A printed product with substantial non-printed paper content, or a kit containing both, is exactly the kind of thing that gets classified differently by different customs authorities. If a line sits near that boundary, the classification is worth confirming rather than assuming.
EUDR is one of four EU regimes now reaching the same parcel from different directions. Packaging registration is covered in the EU packaging EPR marketplace check, product safety labelling in what has to go on a GPSR label, and the duty change on low value consignments in the €3 parcel duty explained. If you are pricing an EU line and want to see what is left after tax and duty before you add compliance cost on top, the EU import VAT and duty estimator will give you the base figure.
Facts verified 2026-08-05 against the sources below. This is a summary for sellers, not legal advice.
Primary sources: Regulation (EU) 2025/2650 of 19 December 2025 amending Regulation (EU) 2023/1115, OJ L, 23.12.2025 — EUR-Lex (Article 1(2) definitions of “downstream operator”, “trader” and “micro or small primary operator”; Article 5 as replaced; Article 1(25) replacing Article 38; Article 1(26) deleting the Chapter 49 line from Annex I; recitals 5 to 7); Regulation (EU) 2023/1115 — EUR-Lex, Annex I; Regulation (EU) 2024/3234 (the first postponement, setting the superseded 30 December 2025 and 30 June 2026 dates); Directive 2013/34/EU, Article 3, as uprated by Commission Delegated Directive (EU) 2023/2775, for the micro, small and medium thresholds; Council of the EU, press release of 18 December 2025; European Commission, Access2Markets note on the delay. Where a point could not be confirmed on a primary source it is flagged as unsettled in the text above rather than stated.