The European Union’s Regulation on Deforestation-free products (EUDR) sparked a global discussion about international efforts to tackle deforestation. With the European Commission (EC) publishing its simplification review of the regulation on May 4, 2026, a new phase is beginning. The debate on trade measures linked to deforestation is increasingly splitting into two distinct conversations: one focused on compliance with instruments such as the EUDR and a deeper exchange about international cooperation on forests, climate, and trade.
These conversations are taking place at a critical moment. The outcomes of the 30th UN Climate Change Conference (COP 30) in Belém, alongside emerging efforts to scale forest finance, suggest that global action on deforestation is entering a new phase, one focused not only on commitments, but on implementation. Whether these different strands can be aligned will shape the effectiveness of the global response.
EUDR: Latest developments
The EUDR has introduced a new level of ambition in addressing deforestation linked to global supply chains. Its core requirements, centred on due diligence, legality (compliance with relevant laws in the country of production), and traceability, aim to ensure that products derived from seven commodities (cattle, cocoa, coffee, palm oil, soy, wood, and rubber) placed on and exported from the EU market are not associated with deforestation.
At the same time, implementation remains complex. Operators and producer countries have raised concerns about administrative burden, data availability, and the costs of compliance, particularly for small and medium-sized enterprises and smallholder producers.
These concerns have already led to adjustments. The original application timeline has been delayed twice, with obligations now applying from December 30, 2026, for large and medium operators and from June 30, 2027, for micro and small operators.
The revision also introduced a new category of downstream operators. Retailers and manufacturers who are not the first to place products on the EU market are now classified as such and are relieved of the requirement to submit full due diligence statements if the product is already covered by a valid statement. Small and micro primary operators in low-risk countries need only to submit a one-time simplified declaration. Printed products such as books and newspapers were removed from scope. Printed products such as books and newspapers were removed from the scope.
Importantly, the revision mandated the EC to carry out a formal simplification review by April 30, 2026. This review reflects a growing recognition that the effectiveness of the EUDR will depend not only on its level of ambition but also on its implementation across diverse contexts. The report published by the EC on May 4, 2026, proposes no further amendments to the core legal text. It considers that the simplification measures introduced since 2023, together with the current package, are sufficient to support implementation.
The package rests on four main elements:
- The updated guidance and FAQs clarify key implementation issues. These include how to verify legality in a proportionate way, the largely passive role of downstream operators in collecting reference numbers, and the simplified regime for micro and small primary operators, including the use of one-off declarations.
- A draft Delegated Act refines the product scope, currently open for public feedback until June 1, 2026. It proposes targeted additions, such as soluble coffee and certain palm oil derivatives, and exclusions, including leather, samples and retreaded tires. After the feedback period, the commission is expected to adopt the act, which enters into force a day after publication in the Official Journal of the EU unless the European Parliament or the Council objects within the scrutiny period.
- The EU Information System, used by operators and traders, is expected to reflect the latest changes and be fully functional from June 2026. It will include new functionalities, such as simplified declarations, registration of new operator categories, and voluntary grouping tools, aimed at facilitating use in practice.
- The EC will establish two repositories ahead of the application date: one on relevant legislation in producer countries and one on certification schemes. These are intended to reduce the burden of legality verification by improving access to information.
The EC estimates that annual compliance costs for companies will fall by around 75%, from approximately EUR 8.1 billion under the original regulation to EUR 2 billion once all simplification measures are considered. At the same time, the EC projects annual environmental benefits of around EUR 7 billion, based on its valuation of avoided deforestation and associated greenhouse gas emissions.
Lastly, the EC report also highlights that as of early 2026, at least 25 producer countries are implementing more than 60 government-led initiatives linked to EUDR compliance, suggesting that the EUDR is shaping and accelerating governance reforms in producer countries.
In terms of next steps, the EC is expected to
- finalize the accompanying implementation tools, including the draft Delegated Act on product scope, upgrades to the EU Information System, and the two new repositories on producer-country legislation and certification schemes.
- continue outreach efforts with operators and producer countries.
- expand partnerships with producer countries through the Team Europe Initiative on Deforestation-free Value Chains.
COP 30 and the Global Landscape
In parallel to EUDR, other deforestation-related developments are taking place. COP 30 in Belém, framed as an “implementation COP,” intended to move beyond high-level commitments and focus on delivery.
At this COP, trade measures were among the most politically sensitive issues. Deforestation-related regulations raised concerns among some countries about potential impacts on developing economies. The decision to continue dialogue on these issues reflects both the lack of consensus and their growing importance.
At the same time, COP 30 reinforced a shift towards implementation. Although not a part of the formal COP 30 collective decision package, known as the mutirão decision, the COP 30 Presidency has committed to advancing a roadmap for halting and reversing deforestation and forest degradation by 2030. As attention turns to COP 31, the key question will be whether this focus on implementation can translate into concrete, coordinated action.
The growing recognition that regulation alone cannot address the structural drivers of deforestation has brought renewed attention to large-scale finance mechanisms that aim to support forest conservation and sustainable production. The COP 30 launch of the Tropical Forest Forever Facility (TFFF) reflects this shift. By seeking to mobilize USD 125 billion from countries, philanthropy and private investors and reward conservation efforts, TFFF aims to address the economic incentives that drive land-use change. However, this initiative does not aim to support the compliance with deforestation-related trade measures, such as EUDR.
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Toward a More Coherent Approach
Taken together, these developments highlight a broader challenge, in which several issues stand out.
First, the distribution of costs and benefits remains uneven. While the EUDR places obligations on operators placing products on or exporting from the EU market, much of the practical burden of compliance falls on producers of the covered commodities under the regulation. This is particularly challenging in contexts where data systems, infrastructure, and institutional capacities are limited. Smallholders are especially at risk of exclusion if these challenges are not addressed.
Second, the link between regulation and finance is still underdeveloped. Without adequate support, compliance requirements may translate into market access barriers rather than pathways to more sustainable production.
Third, implementation challenges and support needs are highly context specific. Drivers of deforestation vary significantly across countries, as do levels of infrastructure, data availability, and institutional capacity. Production structures also differ, particularly in the role of smallholder producers. As a result, approaches to implementation and support cannot rely on a one-size-fits-all approach.
Finally, tensions between trade and climate policies remain unresolved. As seen at COP 30, deforestation-related trade measures are increasingly part of international climate discussions, but consensus on their role and design is still emerging.
What Comes Next?
The EUDR changed the landscape of instruments used to encourage action on deforestation. But regulation alone is not enough. The effectiveness of the global response will depend not on the existence of individual instruments, but on their ability to function as part of a coherent system. Achieving this will require bridging regulatory ambition with implementation capacity and connecting policy frameworks with financial and technical support.
COP 30 showed both the urgency of action and the difficulty of achieving consensus, particularly on issues that sit at the intersection of climate, trade, and development. As the global community moves toward COP 31, the challenge is no longer simply to ensure the ability to comply with trade-related measures. It is to ensure alignment between regulatory measures, producer perspectives, and financial mechanisms.
Ultimately, success in addressing deforestation and enhancing forest conservation will depend on whether the growing range of initiatives can evolve into an approach that is not only ambitious but also workable, inclusive, and scalable. As governments prepare for the Bonn climate talks and COP 31, these are the priorities that should anchor discussions on deforestation and trade measures.
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This article was originally published by the International Institute for Sustainable Development (IISD) and is republished here as part of an editorial collaboration with the IISD. It was authored by Florencia Sarmiento.
