New EUDR Simplifications At A Glance
What You Need To Know & Why It Matters
After the delay of EUDR, the EU Commission is launching a clear message. EUDR is here to stay, and the EU is working relentlessly to make it become a reality. In particular, on April 15, 2025, the EU Commission issued a press release explaining the steps that were and will be taken to simplify the complexity of EUDR and provide further clarifications over the requirements.
This article explores the documents and support that the EU is making available to companies subject to EUDR, while explaining the latest simplifications and their implications for companies subject to EUDR.
The EU supports EUDR enforcement
Last December, the EU Commission, Council and Parliament agreed on the delay of EUDR. On this occasion, the Commission rejected the Parliament’s amendments to the official text, but it promised its commitment to simplifying the requirements.
On April 15, 2025, the EU Commission kept that promise and delivered new material and guidelines that reduce the uncertainty and complexity surrounding EUDR. The list of new materials created since the start of the year and the initiatives surrounding EUDR enforcement is long. The next paragraphs will provide an overview of the material and guidance available.
Updated Guidance Document for Regulation on Deforestation-Free Products
The update of the Guidance document aims to provide further explanations on several topics, including helpful definitions – such as EUDR actors, terminology, agricultural use, … – timelines, due diligence requirements, clarifications on what is meant by “complexity of the supply chain”, legality criteria, product scope, maintenance of the due diligence system, information on composite products, comments on certification schemes and third-party verification schemes.
The 4th edition of the Frequently Asked Questions
The EUDR working group introduced 41 new questions and updated 57 questions in the 4th edition of the Frequently Asked Questions, 22 of which had been introduced only in the 3rd edition. This brings the total to 171 questions with related explanations.
The macro-topics included span across all aspects of EUDR. In particular, the document focuses on the following chapters: the concept of traceability, the regulation’s scope, the subjects of obligations, the definitions, the concept of due diligence, the benchmarking system and partnerships, the digital implementation (the EUDR Information System), the regulation’s timelines, the penalties, and other general matters that did not fit in the above-mentioned topics.
EUDR Draft Delegated Act
The EU Commission has recently released a Draft Delegated Act in response to calls for more clarity regarding certain product groups. This proposed act, now available for consultation, introduces revisions to Annex I of the regulation, specifically focusing on the list of products in scope and those that are exempted.
The publication also aims to gather public feedback across interest groups. Anyone can send their feedback to the Draft Delegated Act until 13 May 2025, after following the instructions for registering and writing a comment.
Benchmarking Classification System
The press release also mentions that the Commission is consolidating the country benchmarking system and will adopt it through an Implementing Act no later than 30 June 2025, following discussions with the EU Parliament.
Other initiatives & materials
EFRAG
April 15, 2025, also represented the deadline for EFRAG to submit to the EU Commission a detailed timeline and plan of work regarding the simplification of the European Sustainability Reporting Standards (ESRS).
This task was officially handed to EFRAG by the EU Commission in March 2025, following the adoption of the Omnibus Package on February 26, 2025, which consists of a broader initiative aimed at cutting red tape and boosting EU competitiveness.
The objectives that EFRAG is supposed to take into account are the following:
- Eliminate less critical mandatory datapoints
- Prioritise quantitative over narrative disclosures
- Clarify which datapoints are mandatory vs. voluntary
- Ensure alignment with global reporting standards
- Provide clearer guidance on how to apply the materiality principle
- Simplify the overall structure and presentation of the standards
The timeline is ambitious, as EFRAG is expected to deliver its full technical advice by October 31, 2025, so that the revised standards can be adopted in time for companies reporting in 2026.
The April 15th deadline was successfully met by EFRAG professionals, delivering a compelling work plan to complete the standards revisions by October.
This also marks a pivotal moment in shaping the future of sustainability reporting in Europe. If done well, the upcoming simplification could make a real difference for companies navigating ESRS, helping them focus on what truly matters while staying aligned with global efforts.
Understanding your position in beef, cocoa, coffee, palm oil, rubber, soy, and wood supply chains
This document, called “Understanding your position in beef, cocoa, coffee, palm oil, rubber, soy, and wood supply chains”, is meant to be examined alongside two other documents, the FAQs and the Guidance documents, both mentioned above, as well as the EUDR official text itself. What is expressed in this material is not legally binding, but it helps understand the Regulation’s requirements.
It is very useful as an overview of how the obligations apply, depending on relevant criteria, such as the company type (operator vs. trader), the company size (non-SME vs. SME) and the company position in the supply chain (first placing vs. downstream) within the EU market. It also provides 11 supply chain scenarios offering real-life examples.
Overview of the main changes introduced
The simplification strategy mentioned in the EU Commission’s press release aims at reducing the administrative costs and burden by 30%. The introduced changes are quite impactful and could revolutionise the approach to EUDR:
- Large companies can reuse previously submitted due diligence statements when re-importing goods that have already been placed on the EU market.
- Authorised representatives are allowed to submit due diligence statements on behalf of company group members.
- Due diligence statements can be submitted on a yearly basis, instead of being filedfor each shipment or batch.
- Clarification of ‘ascertaining‘ that due diligence has been carried out, so that large downstream companies can benefit from simplified obligations. Precisely, they are now only legally required to collect the reference numbers of their suppliers’ due diligence statements and use those references in their own submissions.
All the updated measures are expected to significantly reduce the number of due diligence statements that companies need to file, in response to key industry demands. The goal of these simplifications for due diligence statements is to ensure easy and efficient data entry for all users.
In the next sections, we will analyse the main changes and understand their impact.
Measure 1: Reuse of existing due diligence statements for re-imports
This measure is good news for operators re-importing EUDR material, and we assume it does not apply only to “large companies”. As disclosing geolocation data with the due diligence statement is not mandatory, obtaining it for re-imports as a downstream operator would have been very challenging.
The details for this update can be found in the 4th edition of the EUDR FAQs, precisely in Question 5.4, stating that a DDS for re-imports can be submitted with a reference to the relevant export DDS.
Question 5.4 asks: “What about re-importing a product? What are my due diligence obligations if I am re-importing a product that was previously exported from the EU?”.
First, let’s clarify that a “downstream operator” is an operator that re-imports a relevant product in the EU market by placing it under the customs procedure “release for free circulation”, after it was exported from the EU market. It is important to note that to be able to export the product from the EU market in the first place, the exporter must have submitted a due diligence statement.
The simplification allows downstream operators to benefit from the same simplifications of SME operators, as the downstream non-SME operators (and non-SME traders) are no longer required to perform full due diligence. They are still subject to some obligations, which also apply to non-SME traders. In particular, they must:
- Ascertain that due diligence was conducted by at least one upstream operator (in accordance with Article 4(9) EUDR),
- Submit a Due Diligence Statement (DDS) referencing the upstream DDS, including the relevant reference and verification numbers provided by their direct suppliers.
The official EUDR guidelines provide further clarification on the first step by stating that “ascertaining” that due diligence was correctly exercised does not mean that the operators are mandated to verify the upstream due diligence statements, but at least to check whether the upstream suppliers have an appropriate due diligence system in place.
Despite this simplification, operators must exercise due diligence and submit a DDS for all parts of relevant products that have not yet been subject to due diligence.
The FAQs also clarify that re-imports of material exported before the EUDR enforcement starting date can be imported referencing a conventional DDS reference number that will be communicated by the Commission.
Measure 2: Authorised representatives acting on behalf of company group members
This measure is not completely new and will not reduce the number of DDSs required for compliance across the EUDR-affected supply chain network. It only provides some more clarity on how corporate users can organise the submission process across several entities.
Measure 3: Yearly-based submission of due diligence statements
In reality, the possibility to cover several shipments under an annual DDS was already communicated in 2024 and documented in the FAQs (3rd edition), under Question 5.19, section 4.
However, that Question also indicates that a DDS is specific to assessed harvest events, so that all material covered in a DDS (regardless of whether it is traded in one or several shipments) must exclusively stem from the harvest events considered in the risk assessment conducted for this DDS. As soon as material stems from different harvest events, a new risk assessment and consequently a new DDS are necessary.
This means that the operators and the non-SME traders cannot use the same DDS over and over again. They can only do that if the harvested raw material is the same, and no changes have happened to the supply chain.
In addition, regarding the domestic market, a DDS can only cover the outbound shipments that contain material from a fixed set of inbound referenced DDS. As soon as a new inbound DDS becomes relevant for domestic or export outputs, a new outbound DDS must be submitted.
Thus, Measure 3 only simplifies EUDR compliance and reduces the number of DDS required where all affected material to be placed on the market is sourced from a set of land plots and harvest events known and assessed potentially “ex-ante”.
In the case of the wood commodity and derived products, this will be very challenging in most supply chains. For commodities that are harvested once or several times per year on the same plots, this approach could be more feasible, but there is a potential conflict with FAQ1.18 on reporting in excess, stating that traceability data should be “as granular as possible”.
Eventually, the potential for simplification or reduction of DDS mandated by Measure 3 is unclear, and it raises further questions as it potentially conflicts with published guidance on reporting in excess.
Measure 4: Clarification of ‘ascertaining’ by downstream companies
What does it mean to exercise EUDR due diligence on the domestic market? The discussion emerged right after EUDR publication, as many domestic actors are fully legally liable and may face the same obligations as importing operators.
At the same time, they will receive upstream DDS references from their domestic suppliers and according to Article 4(9) may refer to those after “having ascertained that the due diligence relating to the relevant products contained in or made from the relevant products was exercised in accordance with paragraph 1 of this Article.”
While the legal liability of a domestic actor indicates that they should exercise full due diligence for their EUDR-relevant material, repeating risk assessments of the same material by different actors seems redundant and overly bureaucratic.
According to the revised FAQs, legally liable actors on the domestic market are required, at a minimum, to collect and refer to upstream Due Diligence Statements (DDS) with valid reference numbers. They may also opt to undertake additional activities, such as reviewing information contained in referenced upstream DDS, evaluating the direct supplier’s due diligence system, or conducting a comprehensive risk assessment independently.
However, we consider that to develop an adequate approach to ascertaining, actors need to understand the effect of different activities on penalties in case of non-compliance. What happens if a domestic actor’s outbound statement is traced to a non-compliant statement? If having taken “further steps” beyond mere referencing inbound DDS will not lower the sanction, they have no incentive to engage in any further steps.
In summary, again, Measure 4 is no news, and the potential simplification is unclear, while a reduction of DDS cannot be assumed from this measure. It raises questions regarding the obligations of SME traders and how different approaches to ascertaining will be considered in enforcement.
Wrapping up
Overall, the updated guidance provides some additional clarity and simplification, especially regarding the topic of EUDR re-imports. Regarding the further points mentioned by the EU, more work is needed to achieve true clarification and simplification. Especially, the correlation between “reporting in excess”, the resulting minimum frequency and maximum scope of DDS, and the implications of different approaches to ascertaining upstream DD should be clarified more comprehensively.
RADIX Tree As The Ultimate EUDR Solution
RADIX Tree is an end-to-end solution that enables you to reach supply chain compliance from start to finish without the need for further integrations, partners or contracts.
The platform enables the automated collection and reporting of data. It also provides templates and instructions on which documents are required in each situation, thus reducing the effort and costs for the operator.
Above all, RADIX Tree is the smart tool that minimises the financial impact of supply chain compliance because it offers service packages to suit the size of your business – individually expandable and customisable.
