EUDR for Smallholder Farmers and Micro-Enterprises: Simplified Obligations Explained

Under the EUDR as amended by Regulation (EU) 2025/2650, a micro or small primary operator, meaning a smallholder or micro/small business in a low-risk country that places its own cocoa, coffee, soya or other relevant commodity on the EU market, does not submit a due diligence statement. It submits a one-time simplified declaration and receives a declaration identifier, may give a postal address instead of GPS coordinates, and in most cases does not have to run a formal risk assessment. Micro and small undertakings established by 31 December 2024 also get a later start date: 30 June 2027.

Who counts as a micro or small primary operator

The category was created by Regulation (EU) 2025/2650 and now sits in Article 2(15a) of the consolidated EUDR. All four conditions must be met:

1. Size: a natural person, or a micro-undertaking or small undertaking within the meaning of Article 3(1) and 3(2), first subparagraph, of Directive 2013/34/EU (the Accounting Directive), whatever its legal form.
2. Location: established in a country classified as low risk under Article 29.
3. Own production: it places on the market or exports products that it itself has grown, harvested, obtained from or raised on plots of land (or, for cattle, establishments) located in that country.
4. Commercial activity: it does so in the course of a commercial activity.

There is a useful extension for diversified businesses: an operator that exceeds two of the three Accounting Directive limits can still qualify if it shows that the parts of its balance sheet total, net turnover and average headcount related to the relevant commodities and products stay within at least two of the three limits. The numeric thresholds themselves are set in Directive 2013/34/EU, which is not part of the indexed sources, so check them in that directive.

Which countries are low risk, and why it matters for sourcing

The low-risk list is in the Annex of Implementing Regulation (EU) 2025/1093. It includes, among others, the United States of America, Canada, Ghana, Kenya, Costa Rica, India, Vietnam, Papua New Guinea, the Philippines, Thailand and Uruguay. Any country not listed stays standard risk (Article 1(2) of that regulation), so major producers that do not appear on the list, such as Brazil or Indonesia, are standard risk and their smallholders cannot use the micro or small primary operator regime.

The cooperative row is a reading of the definition, which requires products "that this operator itself has grown, harvested, obtained from or raised". The indexed sources do not address cooperatives explicitly, so treat that line as a point to verify, not a ruling.

What the simplified regime removes, and what it keeps

Article 4a(1) switches off three obligations for micro or small primary operators: submitting a due diligence statement (Article 4(2)), keeping statements for five years (Article 4(3), second sentence) and the ban linked to being unable to complete the statement process (Article 4(4)(c)). Instead:

• One-time simplified declaration in the Information System before the first placing on the market or export (Article 4a(2)).
• A declaration identifier is assigned; products may be placed on the market only after it is assigned (Article 4a(4)).
• The declaration can be updated after any major change (Article 4a(3)).
• No declaration at all if all the Annex III information already sits in a system or database under Union or Member State law, which the Member State then makes available in the Information System (Article 4a(4)). Recital 10 cites EU cattle databases under the Animal Health Law as the model.
• Postal address instead of geolocation for all plots or for the establishment (Article 4a(5)). Recital 9 adds that the address must clearly correspond to the geographic location; the choice between coordinates and address is free.

The regime is lighter but not empty. The Commission's guidance of 20 July 2026 states that micro or small primary operators must still exercise due diligence under Article 8 and keep a due diligence system under Article 12(1). Because they source entirely from a low-risk country, they are not required to carry out the risk assessment and mitigation of Articles 10 and 11 unless they learn of information pointing to a non-negligible risk. In practice, the guidance says, their due diligence system generally consists of the information collection required by Article 9.

What goes into the simplified declaration (Annex III)

1. Name, address and, for goods entering or leaving the EU market, the EORI number.
2. HS code and free-text description with the trade name, plus a one-off estimated annual quantity (in kilograms of net mass for imports and exports, with the supplementary unit where applicable).
3. Country of production and either the geolocation of all plots or the postal address of the establishment or of all plots; for cattle, all establishments where the animals are kept.
4. A fixed text by which the operator confirms it will exercise due diligence and will place products on the market only if no or only a negligible risk is found.

Note the tense: the simplified declaration is forward-looking and filed once, while a due diligence statement confirms due diligence already carried out for specific goods.

The 30 June 2027 date for micro and small operators

Article 38(3), as replaced by Regulation (EU) 2025/2650, delays the core obligations (Articles 3 to 13, 16 to 24, 26, 31 and 32) to 30 June 2027 for operators that are natural persons or micro or small undertakings established as such by 31 December 2024. Everyone else starts on 30 December 2026. The deferral does not apply to products covered by the Annex of the EU Timber Regulation (Regulation (EU) No 995/2010).

The guidance adds a knock-on effect: products placed on the market by a small operator during its transitional period, and products made entirely from them, are not subject to the EUDR obligations further down the chain, provided the operator can show with adequately conclusive and verifiable evidence that the goods were first placed on the market before the deferred date.

What this means for US buyers sourcing from smallholders

• Ask for the declaration identifier. Operators must pass declaration identifiers down the chain (Article 4(7)), and downstream operators and traders whose supplier is an operator must hold them (Article 5(3)). It must also reach customs before release for free circulation (Article 26(4)).
• Check the country, not the exporter. The regime depends on where the producer is established and produced the crop. A smallholder in a standard-risk country is outside it.
• Help with data where needed. Article 11(1) lists support for suppliers, "in particular small holders, through capacity building and investments" among possible risk mitigation measures for operators that buy from them.
• Mandates are possible. Under Article 6(3), an operator that is a natural person or a micro-enterprise may mandate the next downstream operator or trader that is not one to submit the simplified declaration on its behalf; the small operator keeps the responsibility.

The Commission must also assess the role of micro or small primary operators, including the risk of circumvention, in the general review due by 30 June 2030 (Article 34(2)(l)). To test a specific supplier profile, ask the EUDR knowledge base: "We are a micro-enterprise farmer established in a low-risk country who sells cocoa we grow ourselves. Do we have to submit a full due diligence statement like a big importer?"