If you have been following EUDR developments, you will know that there have been significant changes to the core requirements of the legislation and significant simplification since the EU Regulation on Deforestation-free Products became law on 29 June 2023.
Recently, the European Commission published the fifth iteration of the EUDR FAQs and Guidance, along with a suite of materials designed to support the transition from the EUTR (European Timber Regulation). The more comprehensive EUDR includes not only forest products, but also products and commodities that are responsible for deforestation and forest degradation within its scope.
EUDR Timeline
The new simplification measures published in December 2025 have been formally adopted and the European Commission has confirmed that the EUDR will not be opened again. Therefore, the timeline for implementation of the regulation remains as 31 December2026 for non-SME’s and 31 July 2027 for Micro and Small Primary Operators (MSPOs), formerly SMEs.
The EU Traces information platform has been taken offline to configure changes to allow for accommodation of data required within the EUDR regulation, such as submitting Due Diligence Statements (DDS). It is expected to be relaunched during June 2026.
The transition period for the EUTR now runs from January 2027 to January 2030, with the previous cut-off date of 31 December 2020 (after which any commodities within scope must be demonstrably not have come from deforested or degraded areas) remaining the same.
Further changes to the implementation of the regulation
On the 4 May 2026 the European Commission published new FAQs and guidance with some changes to the products in scope for the EUDR. Books, newspapers and printed pictures are now out of scope, whilst pulp and paper (unless recycled) remain in scope. Additionally, palm oil derivatives have been extended to soap; coffee now covers soluble or instant coffee. Re-treaded tyres and used and second-hand products are excluded, as is (potentially contentiously) leather, which has been removed from the scope of the EUDR (see figure below). This change was under consultation until the 1 June 2026, after which the decision on what remains in scope or out of scope will be finalised.
Regarding benchmarking, the system that calculates whether a country is classed as high, medium or low risk of deforestation and degradation remains the same with no zero-risk category added.
The guidance further clarifies the definition of Upstream or Downstream operators/traders with reduced requirements for the newly categorised MSPOs. These smaller enterprises avoid submitting a full Due Diligence Statement by submitting a one-off simplified declaration to EU Traces when first placing a product on the EU market. MSPOs are also able to give a postal address rather than geolocation down to plot level, which is required for larger entities.
FSC Aligned for EUDR solutions
FSC has developed several solutions to complement our Chain of Custody and Forest Management certifications. These tools are relevant for anyone seeking to comply with EUDR or to enable better transparency and due diligence within their supply chains. To support the different elements of the EUDR, FSC Aligned for EUDR has three solutions built around core certification:
- The Regulatory Module — an auditable add‑on that clarifies what certificate holders must do for EUDR‑aligned due diligence.
- FSC Risk Assessments — credible, consistent country‑level risk information.
- FSC Trace — enabling verified transaction data, traceability, and due‑diligence reporting.
Have your say
The FSC Regulatory Module is currently under revision and we are seeking input to ensure continued alignment with the evolving regulatory framework and implementation requirements. FSC is initiating an accelerated revision process for the Regulatory Module. This revision will bring the Regulatory Module up to date with the latest (April 2026) version of the regulation, which will enter into force for large and medium-size enterprises on 31 December 2026. If you wish to have input in the consultation, we encourage certificate holders and stakeholders to take part.
Need to know more?
For more information on EUDR and how you might be impacted, see our Legislation webpages in line with changes. The latest EU FAQs and Guidance along with a newly updated supply chain infographics, which include detailed scenarios, are available from the European Commission website. For companies operating outside the EU, such as those in the UK who are concerned about the impact of the new EUDR legislation on their business, the EC provides information on how the EUDR applies outside the EU. Alternatively, you can check out the FAQs on our website.