With just over six months until the EU Deforestation Regulation (EUDR) takes effect for medium and large companies, the EU Commission has published its Simplification Review, with important implications for those impacted by the regulation.
The Simplification Review was announced in December 2025 during the most recent regulatory amendments. Its intent was to evaluate the administrative burden and impact of the regulation – in particular for micro or small operators – as well as tackle some of the technical issues, such as the reported overloading of the IT system.
The update from the Commission on Monday included a report to the European Parliament and the Council updated guidance document and Frequently Asked Questions, and a draft delegated act on the product scope of the EUDR.
Here we look at how we reached this stage, and where businesses should go next.
How have we got here?
The EUDR was adopted in June 2023, requiring companies to conduct due diligence on seven forest-risk commodity supply chains to ensure that products on the EU market are deforestation-free and legally produced. It applies to products made from a defined set of commodities – cattle, soy, palm oil, coffee, cocoa, rubber and wood – entering or leaving the EU market. Failure to comply leaves companies at risk of fines, exclusion from tenders, and even goods confiscation.
The regulation was originally scheduled to enter into force in December 2024; it has been delayed twice and was formally amended in December 2025 as part of the Omnibus I Package. As well as delaying the regulation, the amendments significantly reduced the data collection burden on downstream companies within the EU and notably simplified compliance for SMEs. They also promised an official Simplification Review to be conducted by the EU Commission by April 2026.
Outcomes of the Simplification Review
The Simplification Review package (accessible here) is more of a practical fine-tuning than a complete re-write. The Commission has decided not to reopen the Regulation and therefore the core requirements have not changed. Importantly:
- The timeline remains the same, with 30 December 2026 enforcement for larger companies and 30 June 2027 for SMEs.
- The country risk classifications have not changed, despite reported pressure for the introduction of a ‘no-risk’ category.
While the regulation is not reopened, the Commission has put forward a draft Delegated Act to amend Annex I: the list of products in scope (full list here). The proposal would remove all leather items and used second-hand items, while adding further palm derivatives, for example certain oil palm-based soaps, as well as soluble or ‘instant’ coffee. The Act is a proposal at this stage, and is open for public consultation until 1 June. The finalised scope will be agreed upon after this date.
What happens next?
- The regulation remains in force and is not being reopened, so companies should focus on preparing for implementation and enforcement.
- Key stakeholders such as companies in the EU have three weeks to provide feedback on the guidance.
- Consultation on the draft Delegated Act ends on 1 June and any changes to Annex I will be confirmed thereafter.
What should companies be doing to prepare?
While the new simplifications provide some clarity, they do not change the core requirements of the regulation and act more as further guidance to the existing text. We recommend that companies focus attention on preparing for enforcement to commence on 30 December 2026.
- Get moving – companies should continue to move forward with preparations with greater confidence that the deadline will be December this year.
- Review HS codes – review product HS codes to assess for any potential new exposures, as well as any products that may no longer be in scope (full list here).
- Check the updated FAQs and guidance – for further detail on any topics of concern. The revised documents provide additional information on legality due diligence and the requirements for responding to substantiated concerns, which have been raised as topics of particular complexity.
3Keel has been supporting clients on EUDR preparedness for the last two years. If you would like to discuss the recent developments with the regulation and what we can do to support, please get in touch with us at commodities@3keel.com or call +44 1865 236500.
