EUDR and SMEs: what changes on 30 June 2027

This guide answers three questions: am I a micro or small enterprise within the meaning of the regulation, when am I affected, and what do I need to put in place right now when there is no regulatory department or dedicated legal counsel.

In brief

Who is a “micro” or “small” enterprise within the meaning of the EUDR?

The regulation does not refer to the SME definition used for public funding, but to the accounting categories of Directive 2013/34/EU (Accounting Directive, EUR-Lex). This distinction is decisive: it determines who is entitled to the postponement and who remains on 30 December 2026.

The thresholds applied

A company belongs to a category if it does not exceed at least two of the three criteria (balance sheet total, net turnover, average number of employees). Exceeding a single criterion is therefore not enough to change category.

* If this was your status on 31 December 2024, and unless the company was already covered by the Timber Regulation (EUTR, European Union Timber Regulation), in which case the date remains 30 December 2026.

Two useful clarifications: Member States may raise the financial ceilings for small enterprises (up to €7.5m balance sheet total and €15m turnover); and the word “micro-entreprise” is a false friend, because the French “micro-entreprise” tax regime does not correspond to the accounting category used by the regulation.

The “SME” trap

In everyday language, an SME with 80 employees is still an SME. Within the meaning of the Accounting Directive, it is a medium-sized enterprise: it falls under 30 December 2026, not 30 June 2027. This is the most costly classification error, because it translates into six months of lost preparation.

Conversely, a TPE (very small enterprise) with 8 people does fall within the micro-enterprise category: it benefits from the postponement, without being exempt from preparing.

Status is assessed at 31 December 2024

Article 38(3) of the regulation, as amended by Regulation (EU) 2025/2650, refers to micro-enterprises and small enterprises “qualified as such on 31 December 2024”. The reference point is therefore fixed in time, as confirmed by the customs codes associated with this exemption (exemption code Y141, French customs).

Practical consequences:

• a company that was small on 31 December 2024 and has since become medium-sized stays on the 30 June 2027 date;
• a company that was medium-sized on that date does not “gain” time by reducing its activity;
• size is assessed according to the accounting rules applicable to your entity; in the case of a group, consolidation or linked company, have the category confirmed by your chartered accountant and check section 3 of the European Commission’s FAQ.

The general framework of the text, the roles and the expected evidence is detailed in our guide to EUDR compliance; this satellite page focuses on what is specific to small organisations.

The date depends on the accounting category, not on the word “SME” used in everyday language.

“[…] micro, small and medium-sized undertakings, irrespective of their legal form, within the meaning of […] Directive 2013/34/EU”Regulation (EU) 2023/1115, Article 2, point 30 · consolidated text, EUR-Lex

What the 30 June 2027 deadline changes - and what it does not

The postponement granted at the end of 2025 shifted the timeline by one year while adding a six-month delay for the smallest organisations. Here is the updated timeline, as published by the Commission (roles and responsibilities, Green Forum).

What the extra time really changes

1. The compliance date. You are not required to have a due diligence statement (DDS) for your own placings on the market before 30 June 2027, depending on your category and your role.
2. The order of priorities. A micro or small enterprise can sequence: classify products and respond to customers first, then equip its processes. A medium-sized enterprise does not have this leeway.
3. The preparation window. Data repositories, geolocation formats and document workflows can be set up gradually, without a forced project.

What the extra time does not change

• The substantive obligation. No deforestation after 31 December 2020, compliance with the legislation of the country of production and due diligence remain required in exactly the same way.
• Responsibility. It lies with the party that places the relevant product on the European Union market for the first time or exports it. No postponement transfers it to a third party.
• Your customers’ contractual requirements. A customer can ask for your data today, with its own deadline, without waiting for the legislator.
• Downstream traceability obligations. Keeping information on suppliers and buyers for five years, and reporting a suspicious product, applies regardless of your size.
• The penalty regime. Each Member State sets its penalties, with a maximum fine of at least 4% of total annual EU turnover in the previous financial year (legal persons), with confiscation and exclusion also possible.
• Other parties’ timelines. Your non-European upstream supplier, your parent company, your medium-sized or large industrial customer: their obligations apply from 30 December 2026, and have a knock-on effect on your dealings with them.

SME operator or SME supplier to a large group: two different worlds

The question “am I affected?” depends on two independent parameters: your size and your role in the chain. The table below covers the most common situations in industrial and food SMEs.

The most common case: the subcontracting SME

Many SMEs are not operators and will therefore never have a statement to submit. Yet they face the strongest pressure, because a manufacturer subject to the 30 December 2026 date must secure its own chain before that date. It will do so by contract: environmental annex, supplier questionnaire, deforestation-free certificate, obligation to provide the geolocation of plots of land, on-site audit, termination clause.

Two rules to keep in mind in this relationship:

• Your customer’s legal date becomes your working date. Signing a clause that promises data by 31 March 2027 creates an obligation for you earlier than 30 June 2027.
• A legal obligation cannot be delegated by contract. A customer cannot transfer its due diligence statement to you: it belongs to the operator placing the product on the market. You can, however, appoint an authorised representative within the meaning of Article 6 of the regulation if you ever have to submit one yourself, and this representative must be established in the EU.

The special case of the data supplier with no direct obligation

If you sell a manufacturer a material or component that contains a relevant commodity, you become an information link: country of production, batch, date of production, net mass, possibly plot coordinates. You have nothing to submit, but you must be able to produce these elements reliably and reproducibly. This is structuring work, not case law.

Lighter obligations and simplified declaration: who is entitled, and who is not

The simplification adopted at the end of 2025 has genuinely reduced the burden, but not for everyone. Three regimes coexist.

The micro or small primary operator (MSPO)

An operator is a “micro or small primary operator” if it cumulatively meets four conditions (European Commission):

1. be a natural person, a micro-enterprise or a small enterprise;
2. be established in a country classified as low risk (country benchmarking);
3. place its relevant products on the EU market or export them itself;
4. be the primary producer of these products: having grown, harvested, obtained or raised them itself.

This regime allows a single simplified declaration to be submitted instead of one statement per transaction. Its content, set out in Annex III of the regulation, is lighter:

Two key points: the declaration is single and is only updated in the event of a significant change; the identifier obtained must be passed on to the first downstream buyer for traceability. Above all, this regime does not exempt from due diligence: it lightens its formalisation.

A French SME that imports, processes or resells does not meet the primary producer condition: it therefore cannot submit a simplified declaration, even if it is small.

Downstream operators and traders: size makes the difference

The first buyer from an upstream operator must collect and keep for five years the statement reference or the simplified declaration identifier it has received, with no obligation to pass them on to its own customers.

What about simplified due diligence?

It exists for products sourced exclusively from countries or regions classified as low risk, with no mixing with unknown, standard or high-risk origins. It removes the risk assessment and risk mitigation steps, but you must be able to demonstrate that there is no mixing. Note: France is a low-risk country, which is not enough if you mix batches of different origins.

What customers will ask of SMEs - even before 30 June 2027

A manufacturer subject to 30 December 2026 cannot wait for your 2027 deadline to document its own chain. Here are the most common requests, and how to answer them without mobilising a project team.

Three method tips:

• Create a one-page “product compliance” sheet, a single one for all requests: product, customs code, origins, suppliers, batches, statement references, attached documents. You will respond ten times faster.
• Track the questionnaires received, with an owner and a response date. An unanswered EUDR questionnaire is often the first finding in a customer audit.
• If you import or export, prepare the link with your customs formalities: the due diligence statement is presented under document code C716, the simplified declaration identifier of a micro or small primary operator under code C717 (French customs).

A realistic preparation plan for an SME without a dedicated regulatory department

Objective: to be able, without hiring, to answer a customer questionnaire and document a product within a few days. The principle is to spread the work across existing functions, at a steady pace, rather than launching a heavy project.

Phase 1 - Scope (month 1)

• List product references and check customs codes against Annex I, distinguishing support packaging from packaging sold as products (see our guide on wood packaging).
• Decide the company’s role for each activity: operator, downstream operator, trader, out of scope.
• Check the size status at 31 December 2024 with accounting and lock in the applicable date.
• Appoint an internal owner, even part-time, and a single point of contact for customers.

Phase 2 - Collect (months 2 to 4)

• Identify upstream suppliers of relevant commodities, with country of production and contact person.
• Send a standard questionnaire, specifying the expected format for geolocation.
• Structure the supplier and customer record required for five years.
• Respond in writing to customer questionnaires already received.

Phase 3 - Structure and test (months 5 to 9)

• Decide where each piece of information lives: ERP (enterprise resource planning), product master data, supplier record, document management (see EUDR and supplier data in the ERP).
• Set up the “product compliance” sheet and version it.
• Run a dry run: rebuild the complete file for one product, from the batch sold to the plot of origin.
• Fix the gaps, then repeat the test on the most exposed product.

Who does what in a small team

The five decisions to make this quarter

1. What is my applicable date: 30 December 2026 or 30 June 2027?
2. Which products and which suppliers should the effort focus on?
3. Who answers customers, and within what timeframe?
4. Where does the information live, and who updates it?
5. Who can represent me if I have to submit a statement?

Common SME mistakes with the EUDR

1. Believing that “SME” automatically means postponement. A company with 80 employees is a medium-sized enterprise: it is affected from 30 December 2026.
2. Waiting until 2027 to contact upstream suppliers. Raw material suppliers will be swamped with requests as the deadlines approach; those who ask first will be the best documented.
3. Confusing the legal deadline with the contractual deadline. It is the signed clause that binds you, not the regulation’s timeline.
4. Agreeing to submit a statement that is not yours. A customer can demand data; it cannot transfer its operator obligation to you.
5. Confusing simplified declaration with small enterprise. The simplified regime is reserved for micro or small primary operators, who are producers established in a low-risk country.
6. Treating the topic as a legal matter. The difficulty is not interpreting the text, but finding the data in the right place, up to date, linked to the right batch.
7. Forgetting timber. Micro and small enterprises already covered by the Timber Regulation remain on 30 December 2026, without benefiting from the six-month postponement.

SME operational checklist

• To check
• Size status at 31 December 2024 documented and validated with accounting.
• Applicable date locked in: 30 December 2026 or 30 June 2027.
• Each product reference classified by its customs code against Annex I.
• Support packaging and packaging sold as products distinguished.
• Company role written down in black and white, activity by activity.
• List of upstream suppliers of relevant commodities drawn up, with country of production.
• EUDR customer questionnaires tracked, with owner and response date.
• Standard “product compliance” sheet created and versioned.
• EUDR clauses in customer contracts reviewed (who provides what, within what timeframe).
• Supplier and customer record kept for five years.
• Split of information between ERP, product master data and document management decided.
• Dry run carried out on the most exposed product.
• Three dates set in the calendar: 30/12/2026, 30/06/2027, 30/12/2027.

Going further

This guide has deliberately left one topic aside: the internal mechanics. An SME that has scoped its perimeter and understood its applicable date still needs to know where each piece of data lives - supplier record, product master data, batches, evidence documents - and how to find it again a year later.