While CLEPA welcomes the Commission’s efforts and the improvements introduced through the May 2026 publication of the Regulation, significant concerns remain regarding legal uncertainty, interoperability, and disproportionate impacts across the industry.
EUDR obligations should be clearly limited to the first operator placing goods on the EU market, typically the importer. Exempting downstream operators fully from Due Diligence Statements (DDS) related obligations would enable a swift and effective implementation by reducing duplication and administrative burden while maintaining accountability where it is most efficient.
Download our Position Paper to see our full list of recommendations.

