On 13 July, the European Commission adopted the final two measures needed to operationalise the EU Deforestation Regulation: a Delegated Act updating the products in scope, and an Implementing Act setting the technical rules for the Information System where due diligence statements will be filed.
The regulatory framework is now settled. What remains cannot be legislated: getting supply chains ready before 30 December 2026, when the Regulation applies to large and medium-sized operators.
What changed in the product scope
The seven commodities are unchanged: cattle, cocoa, coffee, palm oil, rubber, soy and wood remain in scope. The adjustments concern derived products.
- Removed: cattle hides and leather, re-treaded tyres, soybeans for sowing, vulcanised rubber articles, conveyor belts, and aircraft and vehicle seats.
- Added: soluble coffee, certain palm oil derivatives, and frozen cattle tongues. These apply from 30 December 2027, a year after the main deadline.
- Exempted: samples for testing, waste, second-hand products, packing material, and inputs to medicinal products.
For coffee supply chains, soluble coffee is the detail to watch. Instant coffee is a significant share of global coffee trade, and origins supplying that segment will need plot-level traceability just as green coffee exporters already do.
The Information System is live
The Information System reopened at the end of June. The Implementing Act adds simplifications requested by Member States and industry: simplified declarations for micro and small primary operators, and updated specifications for automated APIs. Commission training sessions begin at the end of July.
The API point matters more than it sounds. At cocoa and coffee volumes, due diligence statements will not be filed by hand. Compliance at scale depends on structured first-mile data, collected at the point of purchase, flowing into the EU platform automatically. This is where Farmforce has focused for years: farmer registration, plot mapping and harvest records captured digitally at origin, so the data behind each statement exists before the statement is due.
Five months to go
The Commission has been consistent: the Regulation itself will not be reopened. The dates are fixed. Application starts 30 December 2026 for large and medium operators, and 30 June 2027 for most micro and small operators.
For sourcing organisations, the uncertainty of 2024 and 2025 is over:
- The product scope is defined.
- The guidance is adopted in all EU languages.
- The Information System is operational.
- Training begins this month.
The open question is no longer what the rules will be, but whether first-mile data, plot geolocation, farmer records and legality documentation will be ready when the first statements are due.
Five months is enough time to close that gap. It is not enough time to start from zero.
Sources and further reading
Commission announcement, 13 July 2026
Delegated Act on the product scope
Implementing Act on the Information System
Farmforce provides digital solutions for managing the first mile of agricultural supply chains, from farmer registration and GPS plot mapping to harvest purchasing, deforestation monitoring, and EUDR compliance. To see how Farmforce can support your traceability and sourcing operations, request a demo.
