Live Webinar - Nov 3, 2026 @ 4PM CET - What's Still Missing From Your EUDR File
This piece works through the whole picture: how EUDR measures size, what each category owes in each supply chain role, and the handful of details that move a company from one deadline to the other.
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Short answer: EUDR borrows its size classes from the EU Accounting Directive (2013/34/EU, Article 3), with the thresholds raised in 2023 by Delegated Directive (EU) 2023/2775. A company belongs to a category if, on its balance sheet date, it does not exceed two of the three limits for that category. Legal form doesn't matter. Sole traders, partnerships and cooperatives are measured the same way as limited companies.
A company is large when it exceeds at least two of the three medium limits. Micro, small and medium together make up the SMEs. That matters, because a medium-sized company is an SME for some EUDR purposes but gets none of the extra time.
Three details in that definition change real answers.
You don't need to sit under every limit. A distributor with 60 staff, €8 million in turnover and a €3 million balance sheet exceeds the small headcount limit but stays under the other two. It's a small company. Plenty of operations teams see "50 employees" in a slide and stop reading.
Most people who have applied for EU funding know a different SME test, from Commission Recommendation 2003/361/EC. That one treats headcount as mandatory, uses a €43 million balance sheet ceiling for medium companies, and adds in the figures of partner and linked companies. EUDR doesn't use it. It points to Article 3(1) to 3(3) of the Accounting Directive, which apply to a company's own accounts. The group thresholds sitting a few paragraphs further down that same article are not referenced. On that reading, a small subsidiary is measured on its own figures, not its parent's.
The Accounting Directive lets member states set their own, higher limits for small companies, up to €7.5 million balance sheet and €15 million turnover. Several have, France among them. EUDR refers only to the first subparagraph of Article 3(2), which holds the EU-wide figures of €5 million and €10 million. A company that counts as small under its national accounting law can still be medium for EUDR purposes. If your turnover sits between €10 million and €15 million, check this before you build a plan around June 2027.
Short answer: Under EUDR as amended in December 2025 by Regulation (EU) 2025/2650, your obligations depend first on your role in the supply chain and only then on your size. There are four roles.
The downstream operator category is new, and it moved a lot of large companies. Before December 2025, a large manufacturer that processed EUDR inputs was treated as an operator and had to file its own statements. Now it sits with traders, and neither files a due diligence statement.
If you are unsure which role you hold, that is the first thing to settle.
Short answer: Operators of every size carry full due diligence. Large operators carry extra governance and public reporting on top. Micro and small operators get six more months, and those who sell only their own low-risk production get a one-time simplified declaration instead. Downstream operators and traders file no statements; large ones must register and act on red flags.
Operators
Micro or small primary operators
Downstream operators and traders
An operator's core obligation is identical at every size. Collect the geolocation of every plot the commodity came from, assess the risk of deforestation after 31 December 2020 and of illegal production, mitigate anything above negligible, and file a due diligence statement in the EU information system before the goods move. Keep it all for five years.
A 12-person cocoa importer does the same plot-level work as a multinational. What the multinational adds, under Articles 11(2) and 12(3), is the corporate machinery around it: a named compliance officer at management level, an independent audit of its controls, and a published annual report describing its due diligence system.
The one-time simplified declaration created in December 2025 is the biggest easement in the regulation, and it is often described as "the SME option." It isn't. It belongs only to micro or small operators who place on the market what they themselves grew, harvested or raised, in a country classified as low risk. A small Portuguese forest owner selling eucalyptus it harvested itself can use it. A small Belgian importer buying from growers anywhere, low risk or not, cannot.
Where it applies, it is light: one declaration with name, address, product codes, an estimated annual quantity and the location of the plots or establishment, after which the system issues a permanent declaration identifier that travels with the goods. Where a national database already holds all of that, as with EU cattle registers, the declaration itself can be skipped once the member state shares the data.
No downstream operator or trader of any size files a due diligence statement any more. All of them must hold, for five years, the names, addresses and email contacts of who supplied them and who they supplied. Only the first company after the operator also collects the statement reference numbers or declaration identifiers. Further down the chain, nobody does.
Large companies in these roles take on two more duties. They register in the EU information system before trading. And if they learn, before selling, that a product may not comply, they must tell the competent authority and, where the concern is substantiated, check that due diligence was done and found only negligible risk. Until that check is clean, the product doesn't move.
Medium-sized companies sit with micro and small here. For a downstream operator or trader, being an SME means no registration and no pre-sale verification duty. It does not mean a later date.
The June 2027 date is the most misread line in the regulation. It applies to fewer companies than most people assume, and these are the reasons.
The deferral in Article 38(3) is written for operators. Downstream operators and traders of every size, micro included, start on 30 December 2026. A small distributor whose obligations are mostly record-keeping still has to have those records in place by December.
Micro and small operators handling timber products that were covered by the EU's previous timber rules get no extension. Sawn wood, logs, panels, pulp and paper and most wooden furniture fall in this group. That is why the furniture maker in the opening example is on December and the coffee importer is not. If your products include wood, check the product codes before you check your headcount.
The deferral applies to companies established as micro or small by the end of 2024. A trading company set up in 2025 to import cocoa does not, on a plain reading, qualify for June 2027, however small it is.
When a company established outside the EU places products on the EU market, the first EU-established company that makes them available is treated as the operator. A small wholesaler that thinks of itself as a trader can find itself holding full due diligence obligations because of who it buys from. Size does not change that. It only changes when it starts.
Market shorthand says "SMEs have until 2027." The regulation says micro and small. A company with 180 employees and €40 million turnover is an SME and an operator on 30 December 2026.
An operator that is a natural person or a micro company can mandate the next company down the chain, if that company isn't itself micro, to file the due diligence statement or simplified declaration on its behalf. Responsibility for compliance stays with the micro operator. The paperwork can move.
Are small companies exempt from EUDR? No. Every operator, downstream operator and trader handling relevant products is in scope regardless of size. Size changes when obligations start and, for downstream operators and traders, whether registration and pre-sale checks apply.
What counts as an SME under EUDR? A micro, small or medium company as defined in Article 3 of the EU Accounting Directive. A company qualifies if it stays within two of three limits. For medium: €25 million balance sheet, €50 million turnover, 250 employees.
When does EUDR apply to micro and small companies? From 30 June 2027, if they are operators, were established as micro or small by 31 December 2024, and don't handle timber products covered by the previous EU timber rules. Micro and small traders and downstream operators start on 30 December 2026.
Do medium-sized companies get the June 2027 deadline? No. Medium-sized companies are SMEs, but the deferral only covers micro and small operators. Medium operators, traders and downstream operators all start on 30 December 2026.
What is a micro or small primary operator? A natural person or micro or small company, established in a low-risk country, that places on the market products it grew, harvested or raised itself there. It files a one-time simplified declaration instead of a statement per shipment, and may give postal addresses instead of geolocation.
Do SME traders need to submit a due diligence statement? No. Since the December 2025 amendment no trader or downstream operator files one, whatever its size. They keep supplier and customer records for five years, and the first company after the operator also keeps the statement reference numbers.
What extra obligations do large companies have? Large operators need a management-level compliance officer, an independent audit function and an annual public report on their due diligence system. Large downstream operators and traders must register in the EU information system and verify due diligence when a substantiated concern arises before sale.
Are fines lower for smaller companies? Fines must be proportionate to the environmental damage and the value of the products involved. For legal persons, the maximum must be at least 4% of total annual EU-wide turnover, whatever the company's size. Confiscation of products and revenues also applies.
Most companies will read this and find they are on 30 December 2026. The ones that land on June 2027 should be careful about what they do with the extra six months.
A small operator doesn't sell into a vacuum. Its customers are medium and large companies, and most of them are on December. Their buyers and auditors will start asking for plot data and reference numbers well before the small operator's own date arrives, because their own compliance depends on it. In practice, the supply chain sets the deadline. The regulation only sets the penalty.
The work also doesn't shrink with the company. Collecting geolocation from suppliers who have never been asked for it takes the same months for a 30-person importer as for a 3,000-person one. The difference is that the smaller company has fewer people to do it.
So settle two things this month: your role for each product line, and your size on the EU test rather than the national one. Everything else follows from those two answers.
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