What’s New in EUDR Guidance: Understanding Complex Requirements
14 Jul 2025
With the new compliance dates for the European Deforestation Regulation (EUDR) fast approaching—30 December 2025 for large- and medium-sized companies and 30 June 2026 for small- and micro-sized companies—the EC has released new guidance and tools to help companies in their compliance efforts. Let’s dive into the latest guidance and see how it simplifies the compliance process.
What’s New in EUDR Guidance: Understanding Complex Requirements
With the new compliance dates for the European Deforestation Regulation (EUDR) fast approaching—30 December 2025 for large- and medium-sized companies and 30 June 2026 for small- and micro-sized companies—the EC has released new guidance and tools to help companies in their compliance efforts. Let’s dive into the latest guidance and see how it simplifies the compliance process.
Simplification Through Risk Classification
In May 2025, the EC released the Country Classification List, which assigns risk levels to countries producing commodities covered by the EUDR. The EC had released the list in which approximately 140 countries were classified as low risk; however, the Parliament rejected the list. The favourable classification would have allowed for a simplified due-diligence process in which operators are not obligated to conduct risk assessments detailed in Article 10 of the EUDR and are not obligated to mitigate risks for their commodities. However, until Parliament accepts the results, operators should expect to comply with all articles. It is noted that even with the simplified approach, operators were still required to collect the information as detailed in Article 9 of the EUDR and summarised below. Furthermore, according to the latest guidance, operators with relevant products produced from commodities, even if a low-risk countries, also need to assess the complexity of the supply chain to ensure there is no mixing of products from low-risk countries with products from standard or high-risk countries or with products of unknown origin. There is also some “fine print” in the regulation that essentially states if an operator becomes aware of any information to suggest that a product is not deforestation-free or otherwise is not in compliance with the regulation, then a risk assessment and risk mitigation will be necessary.
Simplification Through Due-Diligence Statements
As part of the due-diligence process, companies must submit due-diligence statements (DDS) before any product is placed on, or exported from, the EU market. As discussed in the recent guidance, the EC has simplified the process by allowing a single DDS to cover multiple batches of the same product or different products, provided all are included in the due-diligence process. As an example, a retailer, acting as an operator, can submit a single DDS covering multiple batches of printed books (HS code ex 49) or wooden tableware items (HS code 4419), provided that the due-diligence process has been completed for both and any risk of non-compliance has been found to be negligible.
However, it is important to remember that combining multiple batches of products under one DDS is more complex and could increase the risk of EUDR non-compliance, as operators remain fully responsible for ensuring accurate and complete information for all products covered by the DDS. Furthermore, if an issue is encountered with one batch of product, it can affect the compliance of all batches under the same DDS.
To develop a deeper understanding of DDS, and to summarise the latest updates and clarifications, Intertek experts have developed a simple acronym: SPARK.
(S) Size: A single DDS with geolocation data must not exceed the 25-MB size limit.
(P) Produced: A DDS only covers commodities already physically produced, including crops already harvested, logs already cut, or cattle born and raised. The final EUDR‑relevant product (e.g., printed books) might not be manufactured at the time the DDS is prepared.
(A) Annual: Due-diligence systems must be reviewed annually and, as a result, a DDS may only cover batches within 1 year of submission.
(R) Risk: The additional complexity associated with the preparation of a single DDS may increase the risk of non-compliance.
(K) Kilograms: A DDS must cover the entire quantity, as kilograms of net mass, of the EUDR‑relevant product placed on, or exported from, the EU market; once that quantity has been depleted, a new DDS is necessary for any additional volume.
It is important to highlight that the quantities stated in the DDS must correlate with the quantities that have undergone due-diligence processes and are intended for placement on, or export from, the EU market. Furthermore, a product batch must only be reported once; more than one DDS cannot cover the same product. This means if a company has already included 100 kg of cocoa beans in one DDS, they cannot declare the same 100 kg again in a second DDS.
Simplification of Information Collection Through HS Codes
When it comes to supply chain due diligence, the HS code plays a crucial role in collecting important information for EUDR compliance. The recent guidance provides additional instructions on the required length of HS codes, allowing for precise identification and classification of EUDR-relevant products along the supply chain.
The latest EUDR guidance states that the HS code must match the minimum number of digits specified in Annex I of the EUDR. As an example, HS code 1806 refers to “Chocolate and other food preparations containing cocoa,” and users may select this code if a more specific subheading is not available. If Annex I indicates a 6-digit code, for example 9406 10 “Prefabricated buildings of wood”, then a broader 4-digit code such as 9406 should not be selected.
Intertek Is Here to Help!
Are you looking for more information about EUDR compliance or do you need clarification on any of the latest guidance? Reach out to Intertek and discover how we can simplify the EUDR compliance process for you. We offer regulatory support and a software solution to ensure that you are fully equipped to meet EUDR requirements with confidence. From understanding the details of your operations to implementing effective systems, we will be with you every step of the way on your EUDR journey.
