10.04.2026
On March 24, 2026, the European Commission presented the guidelines for the upcoming April package on the implementation of the Regulation on Deforestation (RDUE) during the 40th meeting of the Multi-Stakeholder Platform, which was attended by ATIBT among others.
General Guidance from the Commission
The Commission confirmed that it does not intend to reopen the text of the regulation. The ongoing developments are aimed exclusively at improving the implementation of the existing framework through clarifications and technical adjustments.
More than 150 contributions were received, representing approximately 750 questions. However, requests involving changes to the legal text were set aside. Work is currently ongoing with Member States and within the Commission to finalize the package expected by the end of April.
Contents of the April 2026 Package – FAQ: We Look Forward to Your Feedback
The package will include several complementary elements.
First, the Commission is preparing a new version of the FAQs and the guidance document (fifth iteration), aimed at clarifying the practical application of the regulation. These FAQs now constitute a central element of the implementation framework. The main topics covered will include legality, obligations in the downstream chain, the role of micro and small primary operators (MSPOs), and the application of the regulation to online sales.
At this stage, this work is still being finalized. Certain guidelines may therefore still evolve. In this context, it is important for companies to report any implementation difficulties or operational inconsistencies.
ATIBT is available to centralize feedback and relay it to the European Commission and the relevant French authorities to inform the final decisions (caroline.duhesme@atibt.org).
A delegated act concerning Annex I will also be published. This will include targeted adjustments to the scope of products as well as horizontal simplifications previously discussed. A four-week public consultation period is planned, offering stakeholders the opportunity to submit their contributions.
In parallel, the Commission is preparing an implementing act regarding the information system to adapt it to evolving interpretations and improve its operation. Finally, a summary report (“cover note”) will accompany the package to present its overall rationale and quantify the simplification efforts, particularly for small businesses.
Clarifications on obligations in the downstream chain
The Commission has provided a key clarification regarding the identification of downstream actors. It states that a company may be considered a downstream actor once it receives a Due Diligence Report (DDR) number from its supplier.
The obligation to transmit this number rests with the upstream operator. There is no obligation for the downstream operator to actively request it. However, once the number is received, it must be retained for a period of five years.
Overlapping Roles and Associated Obligations
The Commission clarified that when a company imports products, it acts as an upstream operator for those products; if that same company subsequently processes those products and also acts as a downstream operator for the processed products, the due diligence declaration numbers associated with the raw materials must be transmitted to the customer, including for the processed products.
Exports and re-imports
The Commission has also clarified the rules applicable to exports. When an exporter acts as an operator, they must include the due diligence declaration number in the customs declaration. However, when acting solely as a downstream operator, they may use a specific TARIC exemption code.
Regarding re-imports, an importer may be considered a downstream operator if they can demonstrate that the products in question were already placed on the Union market in compliance with the Regulation prior to their export.
Certification
The role of certification under the EU Timber Regulation was discussed during the exchanges.
The Commission confirmed that certification systems such as FSC or PEFC can serve as useful tools for risk assessment and mitigation, particularly in the context of legality and traceability analysis.
Verification and substantiated concerns
Regarding verification obligations, downstream operators may use the due diligence declaration number to access the information available in the system, where relevant.
In situations where information is insufficient or unavailable, it is possible to submit the available information directly to the competent authorities.
Legality: A Risk-Based Approach
The Commission has confirmed that the application of legality requirements is based on a risk-based approach. The information required to demonstrate legality must be tailored to the production area and the characteristics of the supply chain.
When the risk is low, companies are not expected to systematically collect a large volume of information. Conversely, where higher risks are present, additional information must be collected.
Competent authorities are moving toward risk-based controls, prioritizing the supply chains most at risk.
Country benchmarking and risk classification
The Commission confirmed that the current classification system will not be revised as part of the April package.
It reiterated that there is no automatic “zero-risk” category. The fact that a country is classified as presenting a low risk of deforestation therefore does not exempt operators from assessing legality risks.
Changes to the information system
The TRACES information system is currently in read-only mode and is expected to reopen in mid-April. Several significant updates are planned.
Downstream actors that are not SMEs and traders will no longer be required to submit due diligence declarations. Their role will be refocused on registering in the system and verifying the available information.
The system will allow for the verification of the validity of due diligence declaration numbers, including via an API interface. It should be noted that the information system is not a comprehensive traceability tool, but rather a repository for information.
Technical constraints have also been confirmed, including a maximum file size of 25 MB per submission, an API throughput limit, and a number generation time generally ranging from 10 to 15 minutes.
Next Steps
The publication of the April package is expected by the end of the month. It will be followed by a four-week public consultation period for the delegated act. The information system is scheduled to reopen in mid-April. The next meeting of the platform is scheduled for May 2026.
