13.01.2026
On January 6, four workshops were organised to exchange with members and partners on the EUDR simplification regulation adopted on 19 December 2025. The workshops were co-facilitated by Caroline Duhesme (ATIBT) and Alessandra Negri (UICCB / LCB).
The sessions were structured as follows:
– two workshops in the morning for importers and downstream operators, one in French and one in English;
– two workshops in the afternoon for producers established outside the European Union, also one in French and one in English.
In total, around thirty members and partners took part in the discussions, reflecting the diversity of situations encountered in practice across the entire value chain.
Objectives of the workshops
The main objective of these workshops was twofold:
first, to present the key elements of the EUDR simplification regulation, as outlined in the presentation shared during the sessions;
second, to collect in a structured manner the operational questions and practical difficulties faced by companies, in order to transmit them to the French and European authorities and to contribute to shaping the next updates of the Commission’s FAQs.
Discussions focused in particular on the major developments introduced by the text, including the creation of the downstream operator category, the simplification of due diligence obligations for these actors, the central role of the first downstream operator in collecting due diligence statement (DDS) reference numbers, and the introduction of a simplified regime for micro and small primary operators.
It also emerged from the discussions that the new provisions do not affect non-EU timber suppliers, as European importers continue to be considered as “operators” (placing products on the EU market for the first time) and therefore remain subject to all EUDR obligations (due diligence, collection of GPS coordinates, etc.).
Main questions raised by participants
The workshops generated numerous operational questions, reflecting the practical challenges of implementing the regulation. It is still possible to submit your questions to Caroline Duhesme: caroline.duhesme@atibt.org.
(PDF of the questions to be included)
Companies combining several roles
Participants highlighted the complexity of situations in which the same company may act as both an operator (importer) for certain lots and as a downstream operator or trader for others. The differentiated management of DDS reference numbers by lot, as well as the limitations of IT systems (ERP, logistics, invoicing) in distinguishing these situations, were widely discussed.
Traders, downstream operators and “substantiated concerns.”
Strong expectations for clarification were expressed regarding the obligations of downstream operators and traders, particularly concerning the need to know the status of suppliers, the identification of the first downstream operator in the supply chain, and the liability of non-SME companies when they become aware of “substantiated concerns” indicating a risk of non-compliance.
Access to TRACES and non-EU operators
Several questions concerned the use of the TRACES system, including whether an EORI number is required and whether an operator established outside the Union may submit a due diligence statement or a simplified declaration, particularly when located in a country classified as low risk.
Export by a downstream operator
In accordance with Article 26(4), a downstream operator is not required to provide the due diligence statement reference number or the simplified declaration identifier to customs authorities when exporting a product. This interpretation is consistent with Article 2(15), which explicitly excludes downstream operators from the definition of an “operator”, including in the case of export.
Micro and small primary operators
Participants also raised questions regarding the practical application of the simplified regime to micro and small primary operators, particularly when they are established outside the Union and export directly to the European market.
Illegal clearing by third parties
Finally, a sensitive issue concerned situations of illegal clearing carried out by third parties on forest plots. Discussions focused on how such situations should be assessed against the non-deforestation and non-degradation criteria, and on how to distinguish changes linked to harvesting activities from those resulting from exogenous events beyond the company’s control.
Next steps
All these questions have been structured into a working document.
A first version was sent to the French Ministry of Agriculture and Food Sovereignty (MASA) on 9 January, in line with the request of the French authorities. This list may then be completed and consolidated with a view to submission to the European Commission by the end of January, in order to contribute to the official clarification of the EUDR implementation framework and the development of future FAQs.
It remains possible to submit additional concerns, both regarding the simplification regulation and the EUDR requirements that remain fully applicable, such as zero-deforestation and legality checks, GPS data collection, due diligence obligations and the Commission’s country risk benchmarking. Please do not hesitate to send your questions or comments to Caroline Duhesme (caroline.duhesme@atibt.org).
These workshops confirm the importance of ongoing dialogue between companies, professional organisations and public authorities to ensure an effective, harmonised and proportionate implementation of the EUDR.
The Timber Trade Portal: a due diligence support tool
Within the framework of the Tropical Timber Trade Facility (TTT), a project of the German government aimed at promoting legal and sustainable timber trade between the Congo Basin, China and Europe, ATIBT is developing digital tools to facilitate access to reliable information on timber legality and traceability.
The Timber Trade Portal is one of the operational tools of this project. It provides companies and authorities with key information on timber legality, traceability and international trade rules. With the entry into application of the EUDR and new CITES decisions, the portal is currently being updated, including the revision of seven priority country profiles and the update of 29 countries according to a framework aligned with EUDR requirements. The project is funded by GIZ and COMIFAC, and led by ATIBT with the support of LCB.
