EU RD: Commission clarifies roles and simplifies rules for small players
The anti-deforestation regulation is entering its active preparation phase. The European Commission has just published the 3rd edition of its infographics on supply chains in order to help companies find them. An update that incorporates the amendments adopted in December 2025 and significantly reduces the framework for certain actors.
The EU Regulation on products without deforestation (RDEU, or EUDR in English) requires that seven risk categories (beef, cocoa, coffee, palm oil, rubber, soy, wood) and their derivatives placed on the European market be guaranteed without deforestation after 31 December 2020 and produced in accordance with the legislation of the country of origin. In concrete terms, this means traceability to the plot, geolocation, and formal documentation at each stage of the chain.
What the 3rd edition of infographics clarifies is primarily responsible for what. The document distinguishes three types of actors: upstream operators, which place a product on the European market for the first time (importers, domestic producers, exporters) and which must exercise due diligence and submit a Reasoned Due Diligence Statement (SDD); on downstream operators, who work with products already covered by a DDS and do not have to deposit a new one ; and traders, subject to the same reduced obligations as downstream operators. The above diagram summarizes these three categories and their respective obligations.
What really changes with the December 2025 amendments
The substantial novelty of the amendments (Regulation (EU) 2025/2650) is the creation of an unprecedented category: the MSPO, or micro/small primary enterprise. A small agricultural producer, established in a low-risk country under the EUDR benchmarking system, who markets products that he or she has manufactured, can now settle for a single simplified declaration (to be submitted once only) rather than a full DDS for each placing on the market. In some Member States, if the required data are already available in national registers, the operator does not even have to submit the declaration: the Member State makes it directly available in the EU Information System.
The amendments also explicitly clarify that books, newspapers and printing products are now excluded from the scope of application, which is expected to be more precise for those involved in the paper industry. Above all, downstream operators and traders will no longer have to submit a declaration of clean due diligence, which considerably reduces the burden on the chain's intermediate links.
The calendar: more time, but not to wait
Following the publication of Regulation (EU) 2025/2650 in December 2025, large and medium-sized enterprises will have to comply with their main obligations from the 30 December 2026. Micro and small enterprises benefit from a period of 30 June 2027. This second carry-over (after the end of 2024) is mainly due to technical difficulties related to the deployment of the European Information System (TRACES), which must absorb all the operators' declarations. The date of application has been changed, but the basic obligations remain unchanged. This delay is an opportunity for structuring, not an invitation to defer.
Do you have a clear mapping of the risks in your supply chain for the conveniences involved?
What ACTE International recommends
- Identify your precise position in the chain (upstream operator, downstream operator, trader) for each product and flow concerned, it is it that determines your obligations in full.
- Check if your suppliers have already started their due diligence process and get the corresponding DDS reference numbers.
- Establish a system for the collection and storage of traceability documents immediately before deadlines tighten.
- Train your customs teams and supply chain to the EUSR logic: the penalties provided for (up to 4% of annual turnover in the EU, suspension of public procurement) make catching up particularly costly.
CSR & Customs Group Training
We offer specialized training on RDUE regulations, designed for CSR, customs and supply chain teams. A short, operational format to understand obligations and implement them without delay: Raising awareness of deforestation regulation EUDR
- European Commission & UNEP-WCMC, EUDR Supply Chain Infographics (3rd edition), 2026
- Regulation (EU) 2023/1115 on products without deforestation
- Amending Regulation (EU) 2025/2650, December 2025
- Access2Markets v European Commission, update EUDR calendar, 2026