The EUDR was rewritten. So was this guide.
The EUDR you started preparing for is not the one that applies in December
Since the first edition of this guide, the EUDR has been amended, postponed and simplified. The December 2025 amendment reshaped who is accountable for what across the supply chain. The simplification package presented in May 2026, and the delegated and implementing acts adopted in July, filled in the detail. The Regulation now applies from 30 December 2026 for large and medium-sized operators, and from 30 June 2027 for most micro and small operators.
If your compliance programme was built on the original text, parts of it are now out of date, and some of the changes work in your favour.
What this edition covers that the first one could not:
- Two operator categories that did not exist before. Downstream operators and micro or small primary operators now have their own defined obligations, lighter than a full due diligence system, but far from nothing.
- Where due diligence actually sits. Responsibility is concentrated on the first operator placing a product on the EU market. Downstream operators and traders do not file their own due diligence statement; they collect, retain, and act when substantiated concerns arise.
- The low-risk country shortcut. For products from low-risk countries, risk assessment and risk mitigation are generally not required unless there are substantiated indications of non-compliance.
- What enforcement will look like in practice. Competent authorities must check a defined share of companies, and that share rises with the risk classification of the country of production.
- The one-time simplified declaration. Micro and small primary operators in low-risk countries can file once, give a postal address instead of geolocation coordinates, and update only when something material changes.
Written with CMS, a global law firm
This guide was developed with CMS, a global law firm with more than 7,400 lawyers, and LiveEO, specialists in satellite-based supply chain monitoring. CMS supplied the legal analysis of the amended Regulation. LiveEO supplied the operational reality of collecting and verifying geolocation data across thousands of production plots.
It is written for the people who have to make compliance work: compliance leads, procurement teams, and in-house counsel who need to know precisely which obligations attach to their position in the chain, and which do not.
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The legal detail is where compliance programmes fail
Most companies now know they are in scope. Far fewer can answer the questions that decide whether a programme survives an inspection.
- Are you an operator, a downstream operator or a trader, and do you know the answer for every product line you sell?
- Which documents actually evidence legality of production in each of your sourcing countries?
- What are you required to do when a supplier's paperwork is incomplete, or contradicts itself?
- Do your supplier contracts oblige anyone to hand over the geolocation data you need?
- What can a sustainability certification do for you under the EUDR, and what can it not do?
This edition answers each of them:
- A role-by-role breakdown of obligations under Articles 4, 4a and 5, including the two new categories
- Six categories of legality records, with the specific documents that evidence each one
- The penalty regime, including the minimum 4% of Union-wide turnover and what triggers publication of a judgment
- Contract clauses that make suppliers legally accountable for the data your due diligence depends on
- A four-step audit method: information gathering, risk assessment, risk mitigation, verification
Download the guide using the form below
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Five reference tables you can work from directly
New in this edition, and built to be used rather than read:
- Due diligence actions and the evidence each one requires — what to collect at every step, and the tool or document that satisfies it
- Country risk, obligations and enforcement — which duties fall away at low risk, and the share of companies authorities must check in each tier
- Roles and responsibilities across the supply chain — operators, micro and small primary operators, downstream operators and traders, side by side
- Records that evidence legality of production — six legality categories, from land tenure to customs compliance, with the documents that prove each
- Penalties and their consequences — the financial, operational and reputational exposure attached to each type of infringement
Get the 2026 edition
The text is settled, the guidance is published, and the Information System is open. Companies that map their obligations now will spend December placing product on the market rather than reconstructing paperwork.
Download the guide below, or talk to us about how TradeAware handles geolocation data, supplier onboarding and DDS submission end to end.
