May 2026 EUDR Updates - what do you need to know?

EUDR May 4 Updates: What do you need to know?

The European Commission’s May 4 EUDR package puts a clear focus on simplification, while also confirming that the core requirements of the regulation remain in place.

1. Product scope changes

We expect to have more clarity by August or September on where the proposed product scope changes will land. The proposals have been published for feedback in a draft Delegated Act.

The proposed changes include adding soluble coffee and some palm oil-derived products, while removing re-treaded tyres and some cattle products from scope.

Once the proposals are put to the Council and Parliament, and assuming there are no objections, we can expect confirmation by late summer.

Proposed product scope changes - this is currently open to public feedback.

2. Relief for downstream operators

The Commission refers to the role of downstream operators as “passive”. In practice, the focus should be on capturing and retaining upstream reference numbers, rather than duplicating due diligence already carried out earlier in the supply chain.

3. Multiple shipments can be covered under one DDS

There is further clarification on multiple shipments being covered under one Due Diligence Statement. The key points are:

1. Anything sold on the EU market or exported must be covered by the DDS before it is placed on the market or exported.

2. Once the declared quantity has been met, a new DDS is required.

3. A DDS cannot cover more than one year.

4. The goods should already have been produced, harvested, grown or raised — in other words, they should be in existence before the DDS is created.

It is worth noting that covering multiple shipments under one DDS can increase risk. If there is a problem with the DDS, everything covered by it could potentially be found non-compliant.

On a related note, the Information System should be available in June, both for production and testing. This means we can refocus on integrating the API into Sustainimaps.

4. Legality checks should be proportionate to risk

The Commission has indicated that due diligence relating to legality checks should be proportionate to the level of risk. This means more thorough evidence and checks will be expected for high-risk supply chains in high-risk countries than for low-risk supply chains in low-risk countries.

This is specifically mentioned in Section 6B of the Annex to the Communication to the Commission, which states:

“In-depth evidence collection should be prioritised for supply chains, production areas and countries of production where an initial examination of the information available to the operator indicates a higher risk of non-compliance.”

A repository to reference relevant laws in the country of origin, along with relevant certifications, should be available by December 2026.

Overall, the Commission’s communication indicates that it is aware of the financial burden EUDR creates. There is no indication the core legislation will change, however, through guidance to both Member States and Operators, the commission appears to be trying to reduce the administrative burden through a theme of ‘proportionality’. There are several references to ‘proportionate’ due diligence and mitigation and the expectation of proportionate enforcement (ie the audit focus on higher risks).

For now, we need to keep an eye on confirmation of the product scope changes and the release of updated resources: the Information System in June and legality check resources by December. For Trade in Space, our objective remains on simplifying data sharing and reporting from Sustainimaps.

If you have any questions or concerns that have arisen from the May announcements, please don’t hesitate to contact us to discuss.