European Commission published the 3rd edition of the EUDR Guidance Document
SUMMARY:
- Following the targeted amendments adopted in December 2025 to the EU Regulation on Deforestation-free Products (EUDR), the European Commission has published the 3rd Edition of the official guidance document. Members can find the document attached.
- This updated version provides a clearer overview of the obligations applicable to different actors across the supply chain, reflecting the latest revisions aimed at simplifying compliance requirements.
- FESI has also updated its Q&A on the EUDR accordingly (attached); the updated section is on pp. 11-12, in yellow.
MORE INFORMATION:
The document offers detailed explanations and clarifications that complement the revised Deforestation Regulation; in particular, it clarifies the following definitions:
- Upstream operators, who are responsible for exercising due diligence before placing products on the EU market or exporting them;
- Downstream operators and traders, whose obligations primarily relate to traceability and information retention. However, if a downstream operator or trader combines an imported commodity already covered by a due diligence statement with a newly imported commodity not yet covered by a due diligence statement to make a product, they would need to submit a due diligence statement for that newly imported commodity. This is because for that newly imported commodity, that operator or trader would effectively be an upstream operator/trader (more information on pp. 6, 10 and 11 of the Guidance Document).
- Micro or small primary operators (MSPOs), which, when acting as upstream operators, are only required to submit a one-time simplified declaration instead of recurring due diligence statements.
The Commission document also includes concrete and realistic supply chain scenarios concerning specific in-scope materials and products, such rubber and cattle products. These examples help illustrate how different actors are classified and what obligations apply at each stage, making it easier for companies to assess their own position and responsibilities.
