EUDR micro and small operator simplifications: what you actually get

Micro and small operators can get three separate EUDR simplifications, and most assume being small buys them all three automatically. It does not. A six-month extension to 30 June 2027 depends on your products never having been covered by the Timber Regulation. A one-time simplified declaration depends on being a primary producer sourcing only from low-risk countries. Simplified due diligence depends only on where you source from, not your size at all.

The three simplifications, and who actually gets each one

They are independent. You can qualify for one, two, all three, or none, depending on your role, your size and where your product comes from.

Simplification	What it does	Who qualifies
Extended deadline	Obligations start 30 June 2027 instead of 30 December 2026	Micro or small operators and traders, unless the product was already covered by the EU Timber Regulation
Simplified declaration (Article 4a)	One filing replaces a due diligence statement per shipment	Micro or small primary operators — natural persons or micro/small undertakings placing product they produced themselves — sourcing only from low-risk countries
Simplified due diligence (Article 13)	Skips the risk assessment and mitigation steps	Any operator or trader, of any size, where every country of origin for the product is benchmarked low risk

A large importer buying exclusively from low-risk countries gets simplified due diligence but not the other two. A small furniture importer whose products sit under the EUTR carve-out gets none of the three. A small coffee farmer in a low-risk country selling direct gets all three. Check which boxes you actually tick before assuming any of this applies to you.

The six-month extension: 30 June 2027, with one trap

Size is decided by the thresholds in Directive 2013/34/EU: a micro operator has no more than 10 staff, €900,000 turnover and a €450,000 balance sheet; small goes up to 50 staff, €10m turnover and a €5m balance sheet. Exceed two of three criteria in a category and you move up a band. EUDR deadline 2026: which application date applies to you sets out the full mechanics, including how group consolidation can push a nominally small subsidiary into a larger band.

The trap is the EU Timber Regulation carve-out. If your products — logs, sawn wood, panels, plywood, pulp, paper, wooden furniture and the rest of the former EUTR scope — were already caught by Regulation (EU) No 995/2010, being micro or small does not move your date. You are caught by 30 December 2026 regardless of headcount or turnover. EUDR for furniture and timber importers after the Timber Regulation repeal covers which products this catches and why it surprises so many small importers who assume the later date applies to them by default.

The simplified declaration: one filing instead of one per shipment

This is the simplification created specifically for small producers, introduced as Article 4a by Regulation (EU) 2025/2650. It is narrow. You qualify only if all three are true:

• You are a natural person, or a micro or small undertaking.
• You are established in a country benchmarked low risk.
• You are placing on the market, or exporting, a product you produced yourself — this is for primary operators, not traders or importers buying from someone else.

If you qualify, you file one simplified declaration in the EU Information System (TRACES NT) rather than a due diligence statement for every consignment. The declaration carries the information set out in Annex III: identification of the plots of production, legality evidence, and the product's HS code and trade name. Critically, you can give the postal address of your plots instead of precise geolocation coordinates — the one meaningful easing of the geolocation burden anywhere in the regulation, against the polygon and point requirements everyone else still has to capture.

Once submitted, the declaration stays valid indefinitely unless something material changes — a new plot, a change of buyer relationship, a change in the country's risk rating. You receive a declaration identifier, and that identifier is what has to travel downstream with the product, in place of the due diligence statement reference number everyone else uses. In July 2026 the Commission adopted Implementing Regulation (EU) 2026/1565, which set out the technical submission mechanism for this declaration in the Information System — worth knowing if you filed, or tried to file, before that date and found the process incomplete.

Simplified due diligence: available to anyone, not just the small

This is the one people most often confuse with the declaration above, because both involve the word "simplified" and both depend on low-risk sourcing. They are not the same thing, and simplified due diligence has nothing to do with your size.

Under Article 13, if every country of origin for a product is benchmarked low risk, you are not required to carry out the full risk assessment and mitigation process — the documented analysis of deforestation rates, forest presence, indigenous rights, corruption indicators and supply chain complexity that everyone else has to complete and keep on file. EUDR country benchmarking explained: low, standard and high risk sets out which countries currently qualify.

What you still have to do, whatever your size:

• Collect the information a due diligence statement requires — product, quantity, supplier, geolocation of plots, proof of legal production.
• Confirm there is no substantiated concern about the specific supply chain.
• Confirm there is no risk the product has mixed with output from an unknown or higher-risk origin.
• File a due diligence statement, or — if you separately qualify as a micro or small primary operator — the simplified declaration instead.

A large multinational sourcing exclusively from EU member states gets exactly the same simplified due diligence treatment as a five-person importer doing the same. Size is irrelevant to this one.

What being small does not exempt you from

None of the three simplifications removes an obligation outright — each one reduces the volume or frequency of a specific task.

• You still need a due diligence statement, or the simplified declaration if you specifically qualify for it. There is no size threshold below which no filing is required.
• Five-year record retention applies regardless of size, role or risk tier.
• Penalties for non-compliance — including fines calculated as a percentage of EU turnover, confiscation and market exclusion — apply to micro and small operators exactly as they apply to large ones. EUDR penalties: what non-compliance actually costs sets out the figures.
• If you are a downstream trader rather than a primary operator, Do downstream operators and traders still need a due diligence statement? covers what changed for you specifically — most downstream operators no longer file at all, which is a separate change from anything described here.

How to check which simplifications actually apply to you

The three simplifications interact with your size, your role and your sourcing countries differently enough that getting one of them wrong — assuming the declaration covers you when you are a trader, not a producer, for instance — is a common and avoidable mistake. Run the free checker to get your actual deadline, obligations and which of these simplifications genuinely apply, based on your business rather than a general rule of thumb.

FAQ

Does being a micro or small business mean I don't need a due diligence statement at all? No. Every operator placing a relevant product on the EU market needs either a due diligence statement or, if you specifically qualify, the simplified declaration. There is no size threshold that removes the filing requirement entirely.

What is the actual difference between the simplified declaration and simplified due diligence? The simplified declaration (Article 4a) replaces per-shipment filing with one filing, and is only available to micro or small primary operators in low-risk countries. Simplified due diligence (Article 13) skips the risk assessment and mitigation steps, and is available to any operator or trader of any size, provided every origin country is low risk.

Can a small trader who buys from someone else use the simplified declaration? No. It is restricted to primary operators placing product they produced themselves. A small business that imports or trades product grown by someone else does not qualify, whatever its size or sourcing country.

Do I need to be in a low-risk country to get the six-month deadline extension? No. The extension to 30 June 2027 depends on size and product, not sourcing country. It is the simplified declaration and simplified due diligence that depend on low-risk origin.

Does the simplified declaration cover every future shipment automatically? It stays valid indefinitely unless something material changes — a new production plot, a change in your buyer relationship, or a change in your country's risk classification. You do not refile for every consignment, but you do need to update it when the underlying facts change.

What exactly has to go into the declaration under Annex III? Identification of the plots the product came from — geolocation or, for qualifying micro and small primary operators, a postal address instead — evidence the product was legally produced, and the product's HS code and trade name.

Does simplified due diligence apply to large companies too? Yes. It depends entirely on whether every origin country for the product is benchmarked low risk. A large company sourcing only from low-risk countries gets the same reduction in risk assessment work as a small one does.

What happens if the country I source from moves out of the low-risk tier after I've filed? Both the simplified declaration and simplified due diligence depend on the current risk classification. A downgrade from low to standard or high risk removes your eligibility going forward and means you need to meet the fuller requirement for product placed on the market after that point.