European Regulations

Anti-deforestation due diligence 2026: what changes for importers and small operators

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Equipo Editorial CambiosLegales
14 Jul 2026 7 min 4 views

Key data

RegulationCommission Implementing Regulation (EU) 2026/1565 of 13 July 2026
AmendsImplementing Regulation (EU) 2024/3084
Publication14 July 2026
Entry into force13 July 2026
Affected partiesImporters, exporters and operators of raw materials at risk of deforestation in the EU
CategoryEuropean Regulation
Official referenceOJ:L_202601565
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Importers and operators of raw materials sensitive to deforestation have new rules of the game from 13 July 2026. The Implementing Regulation (EU) 2026/1565 amends Implementing Regulation (EU) 2024/3084 and introduces concrete simplifications for micro and small primary operators, while strengthening the resilience of the information system against technical failures.

If your company imports, exports or markets any of the seven raw materials at risk of deforestation regulated by European legislation, this change affects you directly: the forms change, the procedures are updated and there are new contingency routes you need to know about.

What does this regulation establish?

Implementing Regulation (EU) 2026/1565 introduces four blocks of changes to the due diligence declaration system of the EU anti-deforestation regulation (EU) 2023/1115:

ChangeDescription
Simplified declarationsMicro and small primary operators can submit declarations with reduced administrative burden and lower requirements compared to the standard procedure.
Contingency measuresAlternative procedures are established to ensure operational continuity of the information system in case of technical failures.
New submission formatsSubmission formats and procedures are adjusted to improve system usability.
General system simplificationOther measures that facilitate the use of the information system for all operators.

The regulation being amended, Implementing Regulation (EU) 2024/3084, regulates the information system through which operators submit their due diligence declarations under the anti-deforestation regulation. With this amendment, the process is adapted especially to the reality of smaller companies, which until now had to follow the same procedures as large operators.

Economic and operational impact

The main operational impact is the reduction of administrative burden for micro and small primary operators. This translates into less time and resources dedicated to completing declarations, which can represent significant savings in compliance costs for companies with small teams.

For all operators, changes in formats and procedures imply a mandatory update of internal processes: document management systems, approval workflows and declaration models must be adapted to the new requirements before submitting the next declaration.

The contingency measures introduced eliminate a relevant operational risk: until now, a technical failure of the information system could block the submission of declarations and, therefore, commercial operations. With the new alternative procedures, continuity is guaranteed even in situations of system failure.

Who does it affect?

This regulation affects all companies operating in the supply chain of the following seven raw materials at risk of deforestation:

  • Timber and derived products
  • Soy and derived products
  • Palm oil and derived products
  • Cocoa and derived products
  • Coffee and derived products
  • Livestock (bovine) and derived products
  • Rubber and derived products

The company profiles directly affected are:

  • Importers of these raw materials in the EU
  • Exporters from the EU
  • Traders within the European market
  • Micro and small primary operators (with special benefit of simplified declaration)
  • Compliance and supply chain managers in companies in the sector
  • Advisors and consultants managing regulatory compliance for these operators

Practical example

Imagine a small Spanish coffee importing company from Latin American origins, with fewer than 10 employees (microenterprise). Until now, it had to submit the standard due diligence declaration with the same documentary requirements as a multinational in the sector.

With Implementing Regulation (EU) 2026/1565 in force from 13 July 2026, this microenterprise can benefit from the simplified declaration for micro and small primary operators, which requires less information and reduces completion time. Furthermore, if the EU information system suffers a technical failure just before an import, the company can resort to the contingency procedures established to prevent blocking its commercial operations.

The first step for this company is to verify that it meets the criteria of micro or small primary operator according to European legislation, update its declaration templates to the new formats and communicate the change to its compliance manager or external advisor.

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What should companies do now?

  1. Verify if you are a micro or small primary operator: Check if your company meets the size criteria established in European legislation to access the simplified declaration.
  2. Update declaration forms: Replace previous models with new formats adjusted by Implementing Regulation (EU) 2026/1565. Do not use templates from Regulation (EU) 2024/3084 without verifying if they have been modified.
  3. Review internal compliance procedures: Adapt approval workflows, document management systems and internal deadlines to the new submission requirements.
  4. Know the contingency measures: Make sure your team knows how to act if the EU information system suffers a technical failure, using the alternative procedures now established.
  5. Inform suppliers and supply chain partners: If you work with primary operators who can benefit from the simplified declaration, communicate the change to them so they update their documentation.
  6. Consult a specialized advisor: If you have doubts about whether your company is correctly classified or how to adapt your processes, seek specialized legal advice on environmental regulations and foreign trade.

Frequently asked questions

What is the simplified declaration for micro and small primary operators?

It is a new type of due diligence declaration, introduced by Implementing Regulation (EU) 2026/1565, which allows micro and small primary operators to submit their declarations with lower administrative burdens compared to the standard procedure. It is available from 13 July 2026 and applies to operators of the seven raw materials at risk of deforestation: timber, soy, palm oil, cocoa, coffee, livestock and rubber.

When does Implementing Regulation (EU) 2026/1565 enter into force?

The regulation entered into force on 13 July 2026, one day before its publication in the EU Official Journal (14 July 2026). Affected companies must apply the new formats and procedures from that date.

What happens if the EU information system fails and I cannot submit my declaration?

Implementing Regulation (EU) 2026/1565 expressly establishes contingency measures to ensure operational continuity of the information system in case of technical failures. This means that alternative procedures exist that allow declarations to be submitted even if the main system is not available, preventing blockages in commercial operations.

What raw materials are affected by the anti-deforestation regulation?

The seven raw materials at risk of deforestation regulated are: timber, soy, palm oil, cocoa, coffee, livestock (bovine) and rubber, as well as their derived products. If your company imports, exports or markets any of these raw materials or their derivatives in the EU, you are required to submit due diligence declarations.

What regulation does Implementing Regulation (EU) 2026/1565 exactly amend?

It amends Implementing Regulation (EU) 2024/3084, which is the regulation that governs the information system for the submission of due diligence declarations under the EU anti-deforestation regulation. The changes affect declaration formats, submission procedures, simplified declarations for small operators and contingency measures.

Official source

Consult full regulation in official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202601565



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