EUDR ‘Simplifications’: What Changed—‑and What’s Still a Headache

Brussels says the latest tweaks to the EU Deforestation Regulation (EUDR) will shave “about 30 %” off companies’ paperwork load.

Below is a straight‑talk rundown of what’s really easier—and what still keeps operators up at night.

Five things the Commission did make lighter

1. One DDS can now cover an entire year of deliveries rather than one per shipment.
2. Re‑imports may reuse the original DDS reference number instead of creating a brand‑new filing.
3. Authorised reps can file on behalf of multiple group companies, letting office staff shoulder the upload work.
4. Large downstream companies may rely on upstream DDS numbers rather than duplicating the full due‑diligence file.
5. “Change‑of‑HS‑code” clarifications mean that simple processing (e.g., roasting coffee, sawing logs) often turns you into a trader instead of a full‑blown operator, trimming obligations for some mid‑chain players.

Where the “simplifications” still bite

Annual Due‑Diligence Statements

Even though you can file one DDS to cover several shipments, the fine‑print still makes life tricky:

• Quantity lock‑in. The entire volume you’ll ship has to be named up front. As soon as that figure is reached, you must create a fresh DDS for any extra loads.
• 12‑month ceiling. No single DDS may cover goods placed on the market for longer than a year from the day you hit “submit.”
• Only for existing commodities. The logs (or cocoa beans, coffee, etc.) must already be harvested/produced when you file—even if the furniture or chocolate bar they’ll become hasn’t been manufactured yet. In forestry this matters: harvesting, hauling and selling often happen in parallel, so timing the upload is still a juggling act.
• One product, one DDS. A pallet can’t sit under two different statements—duplicates are forbidden.
• Market vs. export guesswork. If you’re not sure which batches will stay in the EU, you can mark everything “export,” but then you have to keep iron‑clad records mapping quantities to final destinations and store them for five years.
• Bigger file, bigger target. Large, mixed DDS files raise your audit risk, because authorities use complexity as one of their red‑flag criteria.

Part of FAQ (April 2025)
“Therefore, in principle a due diligence statement should cover commodities that have already been produced, i.e., grown, harvested, obtained from or raised on relevant plots of land or, as regards cattle, on establishments. In other words, in principle operators should be able to link a due diligence statement to existing commodities. On the other hand, it is not necessary that the individual product that will be placed on the market has already been manufactured: for example, in the case of declaring wooden furniture in a DDS, while the trees should have already been harvested at the time of DDS submission for the furniture, it is not necessary that the furniture has already been manufactured.”

Re‑import

• SME re‑importers may skip fresh due diligence, but they must declare the upstream DDS reference number every time the goods cross the border.
• Non‑SME re‑importers must lodge a brand‑new DDS before the goods re‑enter the EU, even if nothing has changed.
• The same reference number can travel with an export—but only if the lot hasn’t been altered since import.

Part of FAQ (April 2025)
“If the re-importer is an SME operator, Art. 4(8) EUDR applies (see FAQ 5.6.1), meaning the reimporter does not need to carry out due diligence. At customs, the SME re-importer provides the reference number(s) received from its supplier(s) in the customs declaration.
If the re-importer is a non-SME, already existing due diligence statements can help ascertain that due diligence was exercised upstream in accordance with Art. 4(9) EUDR. The non-SME re-importer needs to submit a DDS prior to re-importing and needs to provide the reference number received for its DDS when releasing products for free circulation.”

Large companies

• You must collect and verify every upstream DDS reference and verification number—even when they come from dozens of small suppliers.
• Because SME traders are allowed to pass down only those numbers (no geodata, no risk analysis), large operators still do the heavy lifting to plug the gaps.

Part of FAQ (April 2025)
“Downstream non-SME operators and non-SME traders ascertain that due diligence was exercised upstream by collecting the reference numbers and verification numbers of DDS submitted upstream and verifying the validity of the reference numbers”

SMEs

• You still have to match the right input DDS to the right output even after sorting/mixing goods.
• Downstream SME operators can rely on an upstream DDS only if 100 % of the ingredients in their batch were already covered. One uncertified plank puts them back under full due‑diligence duties.
• SMEs importing raw commodities for the first placement on the EU market still need the whole DDS package—size doesn’t matter in that scenario.
• When exporting, SMEs must still quote every upstream reference number on their customs declaration.

A brighter takeaway — and how the right tool helps you get there

Bottom line: Yes, the Commission took a few bricks out of the paperwork wall—but the wall is still standing. Early preparation and smart data management remain the only sure ways to keep your logs moving when the regulation finally bites.

Automate wherever you can. Spreadsheets will work in a pinch, but dedicated apps cut the risk of a wrong DDS on the wrong pallet.

If you’re looking for one of those apps, Pantiko slots neatly into the gap.

Sign up for any questions or free trial

Sources:

• https://ec.europa.eu/commission/presscorner/detail/en/ip_25_1063