ublication of the third edition of the European Commission guidance document on the EUDR

On 20 July 2026, the European Commission published the third edition of the guidance document for Regulation (EU) 2023/1115 (EUDR – European Union Deforestation Regulation). The document provides clarifications on certain aspects of the Regulation with the aim of supporting its harmonised implementation and helping operators and traders comply with the applicable obligations.

The topics addressed include the definitions of placing on the market and making available on the market, export, operator, downstream operator, micro or small primary operator and trader. In particular, the document clarifies that the role of an entity must be assessed in relation to each relevant product and to its position in the supply chain.

Significant attention is also devoted to due diligence. Operators must collect the required information and documents, carry out the risk assessment and, where necessary, adopt risk mitigation measures. The assessment must consider, among other elements, the country of production, the characteristics of the product, the complexity of the supply chain and any issues relating to legality, deforestation or forest degradation.

The document also clarifies the obligations of downstream operators and traders, who must have access to and retain certain information relating to their suppliers and business customers and, where applicable, references to the due diligence statements. For sourcing from countries classified as low risk, a simplified due diligence regime is provided for, without prejudice to the need to collect the required information and to act where elements emerge, indicating a non-negligible risk.

Finally, the clarification on the timeframe for the application of the EUDR is particularly relevant. Most obligations will apply from 30 December 2026, while for operators established as microenterprises or small enterprises on 31 December 2024, application is deferred to 30 June 2027, with the specific provisions applicable to wood and wood-derived products.

The guidance document therefore represents a reference tool for a proper understanding of the EUDR obligations, while not replacing or amending the provisions of the Regulation itself.

In view of the approaching application dates, it is therefore advisable to start assessing the applicable requirements and preparing the necessary information and documentation in good time. A careful analysis of the supply chain may help identify in advance any aspects that need to be clarified or adapted ahead of the upcoming entry into application of the EUDR.