EUDR Updated Roles

The EU recently published updated guidance on the EU Deforestation-Free Regulation based on the simplification announced in late 2025. The EU Commission recently published an updated infographics document outlining the key roles and responsibilities under the simplified EU deforestation regulation. This document provides a number of scenarios for each of the key commodities under EUDR and it outlines the due diligence responsibilities or lack thereof for the first upstream operator under EUDR, the first downstream operator, the first downstream trader, and any subsequent downstream operators or traders as well as anymemes. es within the supply chain um who are downstream as well. So this document will be very helpful for companies that may have been confused about whether or not or not as a subsequent downstream operator or trader they still needed to submit due diligence statements. The answer is they absolutely do not. whether or not they needed to retain due diligence reference numbers. Again, the answer is they do not. Only the first downstream the first downstream operator needs to retain a a due diligence reference number and they only need to retain that within their own systems. They do not need to submit anything to the EU traces system and they don't need to pass that reference number downstream. This was a major part of the simplification that was agreed upon during trial logs that concluded in December of 2025. So, this infographic document will provide quite a bit of insights to companies that, may have been internally debating about whether or not they needed to retain or pass on those reference numbers depending on where they sat downstream in the supply chain. we also expect the EU Commission to publish updated guidance. Obviously, the guidance that was published in April of 2025 is now quite a bit out of date. it refers to the previous adopted text. So updated guidance will need to be published. that won't be published before the end of April before we get past this period where the commission still has the opportunity to potentially submit any amendments to the existing regulation. so we will need to wait to see whether any changes are submitted before updated guidance is is published from the commission. But updated guidance absolutely is coming. In the meantime, this infographics document should be quite illuminating for companies that are looking to make sure they fully understand what their due diligence obligations look like under this simplified text.