Product Scope

The draft Delegated Act proposes the addition of selected products, such as soluble coffee and some palm oil derivatives (notably soap made with palm oil), and the removal of leather (hides and skin) and retreated rubber tyres from Annex I of the regulation.

The draft further clarifies that the following categories remain out of scope of the regulation:

• Bamboo, rattan, and other materials of a woody nature;
• Single use packaging and packaging material used exclusively to support, protect, or carry another product;
  • Packaging materials/containers suitable for repetitive use;
• Waste, used, and second-hand products;
  • Including products which are made entirely from recycled or recovered material;
• Marketing and information materials accompanying another product, or supplied for marketing or information purposes free of charge.

This draft Delegated Act is currently open for public feedback until 1 June 2026.

Clarification of obligations for downstream operators and traders

Downstream actors must collect and keep information as it relates to their direct business partners, e.g. name, postal address, email address, etc; this information is to be collected and kept outside of the EUDR information system.

Only when the direct supplier of a downstream actor is an operator, making said downstream actor a first downstream operator or trader, must the DDS reference numbers of the relevant products also be collected and retained. The obligation to pass along the reference numbers lies with the operator.

Non-SME downstream operators and traders must still register in the Information System and verify that due diligence was exercised for relevant products, before making available/placing relevant products on the market.

Legality criterion

To support compliance with Article 9(1)(h), the Commission will set up repositories of relevant legislation of the country of production and of certification schemes. Operators may use the information provided in the repositories as the basis for determining if further examination and information collection is required.

Two repositories will be established:

1. Listing relevant legislation of the country of production
2. Listing certification schemes applicable to EUDR-relevant commodities

The repositories will be hosted on dedicated websites which the Commission plans to launch by December 2026.

Information System

The Information System has been temporarily closed and is slated to be reopened in June 2026 (training and production environments).

The main functionalities being introduced include:

• Submission of simplified declarations following existing DDS format
• Registration of roles (e.g. non-SME downstream operator or trader)
• Mechanisms to support competent authorities in analyzing geolocation data

Updates to the system will be ongoing throughout the summer, and will include new user instructions, guidance on geolocation data handling, and the description of error codes.