EUDR for Smallholders and Micro-Enterprises: The Simplified Regime Explained

Since Regulation (EU) 2025/2650, a smallholder or micro/small business established in a low-risk country that places its own cocoa, coffee, timber or other relevant commodity on the EU market is a micro or small primary operator. It files a one-time simplified declaration rather than a due diligence statement for each consignment, may use a postal address rather than coordinates, and generally need not carry out a formal risk assessment. Separately, micro and small undertakings established by 31 December 2024 apply the rules from 30 June 2027 rather than 30 December 2026, with an exception for timber products covered by the EU Timber Regulation.

This article explains the EU rules only, using the official texts indexed in the EUDR knowledge base; it does not cover UK domestic legislation.

Why the EU created a separate category

Recital 7 of Regulation (EU) 2025/2650 acknowledges that the original EUDR placed "an administrative burden on micro or small producers that place on the market or export their own products". To relieve them, and to reduce the load on the Information System, the legislator introduced a subcategory of operators to whom the obligation to submit a due diligence statement does not apply. Recital 8 explains why a one-time declaration is still required: traceability, automatic risk assessment by the Information System, and risk-based checks by the authorities.

The four-part test

Article 2(15a) of the consolidated EUDR sets out the definition. Use it as a checklist:

1. Is the business a natural person, or a micro or small undertaking under Article 3(1) or 3(2), first subparagraph, of Directive 2013/34/EU, regardless of legal form? The thresholds are in that directive, not in the indexed sources.
2. Is it established in a low-risk country under Article 29?
3. Does it sell what it has itself grown, harvested, obtained or raised in that country?
4. Is it the operator, i.e. the one placing the goods on the EU market or exporting them?

There is a safety valve for groups with wider activities: a business that exceeds at least two of the three size criteria can still qualify if the share of its balance sheet, net turnover and average workforce attributable to the relevant commodities and products stays within at least two of the three limits.

Low-risk countries: the UK is on the list

The Annex of Implementing Regulation (EU) 2025/1093 lists the United Kingdom of Great Britain and Northern Ireland as low risk, alongside all EU Member States and producer countries such as Ghana, Kenya, India, Vietnam, Papua New Guinea and Costa Rica. Countries not listed remain standard risk; only Belarus, North Korea, Myanmar and Russia are high risk.

What the regime replaces

• No due diligence statement per consignment (Article 4a(1) disapplies Article 4(2)).
• One simplified declaration, filed once in the Information System before the first placing on the market or export; the system assigns a declaration identifier, and goods may move only after that (Article 4a(2) and (4)).
• Updates only after major changes (Article 4a(3)).
• Possible exemption from filing where all Annex III information already sits in a database under Union or Member State law and the Member State shares it through the Information System (Article 4a(4)).
• Postal address of all plots or of the establishment instead of coordinates (Article 4a(5)); Recital 9 requires that it clearly corresponds to the geographic location.

Annex III lists the content of the declaration: name, address and, for goods entering or leaving the EU market, EORI number; HS code, description, trade name and a one-off estimated annual quantity; country of production with coordinates or postal address; and a fixed text committing the operator to exercise due diligence and to place goods on the market only if no or only a negligible risk is found.

What the regime does not remove

The Commission's guidance of 20 July 2026 is clear 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 need not perform the risk assessment and mitigation of Articles 10 and 11 unless they become aware of information pointing to a non-negligible risk. Generally, their system will consist of the information collection in Article 9.

• Products must still be deforestation-free, with a cut-off date of 31 December 2020, and legally produced under the law of the country of production (Article 3).
• Submitting the declaration means assuming responsibility for compliance (Article 4(3)).
• Authorities may examine the simplified declaration when checking operators (Article 18(1)(b)).
• Penalties under Article 25 apply to operators generally, including fines whose maximum must be at least 4% of total annual Union-wide turnover for legal persons.

The 30 June 2027 deferral, and the timber exception

Article 38(3) defers the core provisions to 30 June 2027 for operators that are natural persons or micro or small undertakings established as such by 31 December 2024. This deferral is about size and date of establishment, so it is wider than the micro or small primary operator category. It does not apply to products covered by the Annex to Regulation (EU) No 995/2010, the EU Timber Regulation. The indexed sources do not reproduce that annex, so a small timber business should check whether its products fall within it.

According to the guidance, products placed on the market by a small operator during its transitional period are not caught downstream either, even after the date, as long as there is adequately conclusive and verifiable evidence that they were placed on the market before it.

Practical steps for UK buyers of smallholder produce

1. Map which suppliers sit in low-risk countries and could file a simplified declaration.
2. Ask them for their declaration identifier; operators must pass it on (Article 4(7)), and downstream operators and traders must hold it where their supplier is an operator (Article 5(3)).
3. Where suppliers lack capacity, consider the measures Article 11(1) mentions for operators: supporting suppliers, in particular smallholders, "through capacity building and investments".
4. Note that under Article 6(3) a natural-person or micro-enterprise operator may mandate the next actor down the chain (not itself a natural person or micro-enterprise) to file the simplified declaration for it, while keeping responsibility.

The Commission must review the role of micro or small primary operators, including the risk of circumvention, by 30 June 2030 (Article 34(2)(l)). For a specific case, the EUDR base answers questions such as "Can a micro or small primary operator give a postal address instead of exact coordinates for their plots?"