What is the EUDR transition period, and who does it apply to?

The EUDR transition period refers to the phased implementation that the EU has implemented for micro and small primary operators (MSPOs) to comply with the Regulation. While large and medium operators and traders must comply with the EU Deforestation Regulation by December 30, 2026, small and micro primary operators - which refers to a new category defined during 2025's EUDR simplification - do not need to comply with the regulation until June 30, 2027. Here are a few clarifying points around the EUDR transition period, who it applies to - and who it does not apply to.

Which companies are MSPOs?

First, it is important to define micro and small primary operators. Unlike SMEs (small and medium sized enterprises), MSPOs are a new category of micro-sized operator who, critically, is placing EUDR-relevant goods on the market for the first time. MSPOs are a specific subcategory for individuals or micro-enterprises that produce, grow, or harvest relevant raw materials themselves in low-risk countries.

Only MSPOs are subject to the EUDR transition period. While SMEs have simplified obligations under the law, SMEs are required to comply with the regulation by December 30, 2026 along with large operators.

Can EUDR-relevant goods be placed on the EU market during the transition period?

Yes. EUDR-relevant goods can be placed on the market during the transition period, even if they are mixed with goods that are not subject to the transition period. (If the latter is the case, the goods must still comply with the regulation by submitting a DDS for the material / commodities that are subject to the December 30th deadline).

If, for example, a large company is the first downstream operator for a product where an MSPO is not required to submit any information to TRACES related to that product during the transition period, the first downstream operator would simply make use of the conventional due diligence reference number (provided by the EU Commission) on any customs documentation to indicate that the product entering the EU market does not require a DDS or declaration identifier.

The intention of the EUDR transition period is not to halt the flow of products into the EU market - only to allow companies subject to its benefits additional time to comply with the regulation's requirements.

To learn more about how Sourcemap's policy team can help your company identify your EUDR risk exposure, reach out to our team of experts today.