EUDR deadline for small businesses: 30 June 2027, and who files what

Application dates

Size is judged under the EU Accounting Directive (2013/34/EU) for each legal entity, not the group. For the 30 June 2027 date, Article 38(3) and the Commission's FAQ say what matters is whether the operator was established as a micro or small undertaking by 31 December 2024. The later date covers operators only: the Commission's Access2Markets summary lists downstream operators and traders of all sizes under 30 December 2026.

Who submits the due diligence statement now

• The operator who first places the product on the EU market, or exports it, submits the statement. The Commission names importers and primary producers placing directly on the EU market.
• Downstream operators and traders no longer submit their own statements, and the Information System does not let them.
• They still collect and keep, for at least five years, the details of their suppliers and customers. The first business downstream of the operator also keeps the statement reference numbers the operator passes on.
• Micro and small primary operators, such as farmers, in low-risk countries submit a one-off simplified declaration instead, which can use a postal address in place of coordinates.
• A non-EU operator can use the Information System only with an EORI number issued by an EU member state (or an XI number for Northern Ireland), and submits before the customs declaration is lodged.

What is covered

The regulation covers seven commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood. It applies only to the products listed in its Annex I, which includes derived products such as chocolate, tyres and furniture. The Commission updated the Annex I list in 2026 (Delegated Regulation (EU) 2026/2102); the products it added, such as soluble coffee, certain palm oil derivatives and frozen cattle tongues, apply from 30 December 2027. Check your HS codes against the current version rather than an older summary.

What the geolocation must look like

• Latitude and longitude to six decimal digits; the Information System truncates longer values.
• Polygons for plots over 4 hectares, except cattle establishments, which can be a single point. A circle around a central point does not count as a polygon.
• A single point is allowed for plots under 4 hectares.
• GeoJSON only, in the WGS84 coordinate system, with longitude before latitude.
• Up to 25 MB per statement submission; the Commission suggests removing unnecessary points on straight edges to keep files small.
• There is no exception for low-risk countries: geolocation is still required.

What changed in 2026

The December 2025 amendment asked the Commission for a simplification report by 30 April 2026. The Commission published it on 4 May 2026. According to Baker McKenzie and Linklaters, it proposed no changes to the regulation's text, and the existing timelines continue to apply. Alongside it, the Commission published updated guidance and a fifth version of its FAQ, dated April 2026.

Checklist for a small importer

• Confirm your size category as it stood on 31 December 2024, and so your date.
• For each product, confirm whether you are the operator (you import it or produce it) or downstream (you buy it inside the EU).
• Check each HS code against the current Annex I.
• Ask every supplier for plot geolocation now; this is usually the longest step.
• Register in the EUDR Information System and plan to submit each statement before the customs declaration.
• Set up a way to pass statement reference numbers on to your customers.

Where Origin Pack fits

Origin Pack does the data work for small operators: a €15 scope check, then for €99 per product line a validated GeoJSON plot file, a draft due diligence statement and a list of what is missing. You keep control of the risk assessment and submit the statement under your own account.

Questions