EUDR April Review Webinar Q&A

Following our EUDR webinar on 12 May 2026, we’ve pulled together answers to some of the most common and complex questions raised during the session. The discussion covered everything from composite products and downstream operator obligations to paper traceability, e-commerce, TRACES functionality, and the practical implications of the EU Commission’s latest April Review clarifications.

The answers below reflect the latest available guidance, including Regulation (EU) 2025/2650, the 3rd edition Guidance Document, and the 5th iteration FAQs published on 4 May 2026. As implementation continues to evolve, we expect further technical guidance and clarification over the coming months, particularly around TRACES and product scope.

Whether you’re still determining whether your products are in scope, clarifying your role in the supply chain, or trying to operationalise due diligence requirements, these FAQs are designed to help businesses navigate the practical realities of EUDR compliance.

Q1. Composite products - if an item is not covered by a relevant HS code but has, for example, a wooden lid attached, is it outside scope (like a car with leather seats)?

A. Correct. EUDR scope is determined by the CN/HS classification of the finished product listed in Annex I, not by the individual materials contained within it. If the finished product's CN code is not listed in Annex I, the product is generally outside EUDR scope even if it contains a relevant commodity such as wood or rubber. For composite products that are themselves in scope, due diligence applies only to the relevant Annex I commodity contained in the product.

Refer to FAQs 2.1, 2.2 & 1.3

Q2. If you meet the criteria of a micro/small primary operator (MSPO) but are outside the EU clearing customs as the operator, can you qualify?

A. The amended framework does not explicitly require an MSPO to be EU-established. However, practical operation of the EU Information System/TRACES may still require EU Login access (or formal agreement with an Authorised Representative). The definition of an MSPO stipulates that it must be registered in a country defined as low risk per EUDR benchmarking. 

Q3. Do you offer 1-2-1 reviews to help a business establish its roles and obligations?

A. Yes - we offer consultations covering EUDR scope assessment, supply-chain role analysis, operator/trader qualification, due diligence obligations, and the impact of the December 2025 amendments on specific value chains. You can book this directly via our website or contact@iov42.com.

Q4. Does EUDR give platforms such as Temu, Shein, and non-EU online retailers a commercial advantage over EU retailers?

A. This is an interesting question which has given us food for thought, so thank you. 

In so far as EUDR is clear that B2C (business to consumer) sales are not in scope of EUDR, there is an equal footing for downstream activities for online retailers whether they are based in the EU or not. The same stands for the position of marketplaces being deemed intermediaries rather than Operators. 

Correct coding still needs to be applied on customs documentation if purchases are facilitated by non-EU platforms. It may be that for EU platforms, if they are a Subsequent Downstream Operator (i.e., they purchase internally within the EU from Downstream Operators), they do not have to manage customs clearance (unlike non-EU platforms). 

Generally, enforcement against high-volume direct-to-consumer trade remains operationally challenging. Separate EU customs reforms, marketplace liability developments, and Digital Services Act (DSA) enforcement actions are expected to strengthen oversight of these activities over time.

Q5. Does this mean non-EU suppliers can supply non-compliant products directly to EU consumers?

A. The same challenge and potential loop hole comes with manufactured products which contain non-compliant products, but are imported from outside of the EU under an HS code not included in Annex 1. 

The lesser obligations for sales to consumers come with the caveat that the consumer must never supply the product further onwards on the market. 

Refer to FAQ 3.7: “In the specific case of B2C e-commerce transactions (See FAQs 3.17-3.19), Art. 7 EUDR does not apply to EU consumers buying products for private consumption from outside the EU, as such consumers do not make relevant products available on the EU market. Art 7 EUDR does not require that there must be an operator established in the EU when a relevant product is supplied to a final consumer.”

Q6. Do UK online suppliers selling to EU consumers have obligations under EUDR?

A. UK online suppliers will have ‘procedural’ obligations, but not legal responsibilities under EUDR. 

A UK online supplier placing goods on the EU market (“releasing for free circulation”) will take on the role of a non-EU Operator under EUDR. It will need to set up a TRACES account, conduct due diligence and submit a DDS per transaction. But there is no legal obligation under EUDR for non-EU Operators. 

Refer to FAQ 3.7 as detailed above.

Q7. As a UK (non-EU) non-SME downstream operator, do we need to register with TRACES?

A. Based on how you’ve classified yourself, we expect that you refer to scenarios where you are a UK supplier, sending EU customers products which have already been placed on the EU market (re-importing). Technically, you would be a non-EU supplier, or non-EU Operator. The latter being when “release goods for free circulation” in the EU. 

When acting as a non-EU Operator, you would be able to either add to the customs documentation the upstream DDS references, or the conventional reference number used for re-imported goods. We do not believe that you would be required to submit a new DDS to TRACES. 

In this instance, it is not clear in the legal text whether you, as a non-EU, non-SME operator, would need to register with TRACES. It may be advisable to do so just in case. What is clear is that you would not be legally responsible for EUDR compliance (as a non-EU operator). 

Q7. Do we know if EUDR is in scope of the SPS Agreement?

A. SPS is a European Sanitary & Phytosanitary agreement which relates to the trade, production and movement of plants, animals and their derived products. EUDR is a separate, technical regulation rather than as an SPS measure. SPS measures typically concern food safety, pests, or disease risks, whereas EUDR is based primarily on environmental and deforestation objectives.

As we understand it at the moment, EUDR is not in scope of the SPS Agreement. 

Q8. We are a medium-sized EU business (excluded from CSDDD and CSRD). Is there a reference for what the annual reporting should look like under EUDR?

A. EUDR annual reporting obligations are separate from CSDDD and CSRD scope. 

Only Upstream Operators who are not MSPOs have annual public reporting requirements. Downstream Operators do not need to report annually. Refer to the latest ‘EUDR supply chain infographics’ document. 

Article 12 is worth looking at and outlines general expectations and describes reporting on an operator’s due diligence systems and the steps taken to conduct due diligence and risk assessment procedures. It also describes that the annual public reporting obligations for EUDR can be combined with annual reporting obligations for other EU legislation, such as the CSRD and CSDDD. 

There is no mandatory reporting template at this stage, and we don’t necessarily expect there to be one. The recent FAQs (5.14) outlined that an operator’s first annual report does not need to happen before 30th December 2027 (1 year after enforcement). 

Refer to Article 12 of EUDR legal text and FAQ 5.14.

Q9. What is the current guidance for the paper industry, given the difficulty of segregating wood pulp back to forest plot?

A. The latest publications from the EC do not provide specific guidance for each sector, other than the diagrams in the supply chain infographics document. For paper specific advice, we recommend you reach out to your national trade associations or CEPI (https://www.cepi.org/). 

The requirement for plot-level geolocation traceability has not been adjusted. Traditional mass-balance approaches as a substitute for traceable due diligence where compliant and non-compliant material are mixed without sufficient traceability controls are not accepted under EUDR.

Like with palm oil silos, pulp and paper mills are often unable to physically segregate raw materials. Therefore the EC’s suggested mechanism (refer to FAQ 1.18) to ‘declare plot locations in excess’ is being widely adopted by our paper clients. This is more easily achieved where there are monitored ‘first in, first out’ manufacturing processes or where there are regular stock takes. Without this, the operator may end up with an ever increasing number of DDS to link to products. 

Where you do not have the ability to directly link pulp inputs to paper outputs, declaring all possible species and plot level locations in the paper output is allowable under EUDR with the following conditions:

• You must have conducted due diligence on all of the potential plots and species covered by the DDS (or due diligence information shared with EU customers in the case of non-EU pulp and paper mills)
• Non-compliance of any one single plot would render all paper covered under the DDS non-compliant
• DDS submitted for mixed products can cover a maximum period of 12 months due to the requirement to review due diligence systems every 12 months (refer to FAQ 5.19)

Refer to FAQs 1.17 & 1.18 & 5.19

Q10. Paper mills will be reporting in excess for paper — is that the correct interpretation?

A. Yes, as we understand it, paper mills will be likely to rely on the declaration in excess for paper. This could involve overdeclaring potential points of origin and species as well as volumes. 

Importantly, all overdeclared data points must be backed up with evidence of due diligence and zero risk conclusions. 

Recent FAQ 5.19 outlines that any difference between volumes declared in DDS and volumes placed on the EU market must be explainable and documented within due diligence systems. 

The EC is clear that declaring excessive plots of land (i.e., whole countries or regions) is not permitted under EUDR (refer to FAQ 1.17), but we don’t believe this is what was behind your question. 

Q11. What about exporting EU paper (Chapter 47), converting it into a notebook or birthday card (Chapter 48 or 49), and the DDS information required at that point?

A. The guidance on this was recently updated by way of FAQ 3.7. Applying it to the question here, a non-EU business sells paper (in scope of EU) to an EU entity, and because it is made of EU pulp, it is a re-import. The conventional DDS reference for reimported goods should be referenced on the customs declaration if the original DDS references are not available (refer to FAQ 5.4).

• If the non-EU business imports the goods as a non-EU Operator, and sells the goods to an EU entity who converts them into an out of scope product (e.g., HS49, printed materials), then the EU entity is not supplying in-scope products and therefore has no EUDR obligations.
• If the non-EU business imports the goods as a non-EU Operator, and sells the goods to an EU entity who converts them into an in-scope product (e.g., HS 48, paper materials), then the EU entity is likely to be a Subsequent Downstream Operator (since the paper had previously been placed on the EU market) and has limited obligations. 

In both scenarios, Downstream EU Operators do not have to submit DDS or conduct due diligence. They are obliged to keep upstream supplier information, including any reference numbers they receive, on record for 5 years and report in the case of any substantiated concerns. 

Q12. Has the ability to nest DDS definitely been removed from EU TRACES?

A. Until we see the details of the Implementing Act, there is no updated technical guidance on TRACES. We know that one of the elements being worked on was ‘voluntary grouping’ functionality, though the details on this are sparse. We will circulate an update as soon as anything official is published. 

Reference links

• EUDR FAQs (5th iteration, May 2026)
• EUDR Guidance Document (3rd edition, May 2026)
• Draft Delegated Act on product scope (open until 1 June 2026)
• Micro, small or medium business under EUDR (Interu)
• Are my products in scope? — Webinar Q&A (Interu)
• EUDR transition periods and stocks (Interu)
• Previous Interu webinars

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