EUDR and SMEs: Three Assumptions You Can’t Afford to Make

Across conversations with SMEs preparing for the EU Deforestation Regulation, the same three beliefs come up repeatedly. While they are understandable, they can lead to significant compliance gaps. In each case, the cost of holding onto them is measured in time, supplier relationships, and in some cases contracts. 

These assumptions are common for good reason. EUDR involves multiple requirements, has been revised over time, and guidance for smaller companies has evolved throughout the process. But as the December 2026 deadline for medium and large operators approaches and the June 2027 deadline for smaller companies follows closely behind, the window for acting on incomplete information is closing. 

Assumption 1: “EUDR only applies to large companies” 

The EUDR applies to every company that places in-scope commodities or derived products on the EU market, regardless of size. There is no minimum revenue threshold, no employee count exemption, no carve-out for family-run businesses. 

What does differ by size is the timeline. Small and micro companies have until June 30, 2027, to comply, while medium and large operators face a deadline of December 30, 2026. This is a meaningful distinction, but it is not an exemption. 

Assumption 2: “My supplier handles it, not me” 

This assumption contains a partial truth, which is what makes it dangerous. For downstream traders (wholesalers, distributors, and retailers handling products that have already been placed on the EU market), it is correct that your supplier handles the Due Diligence Statement submission. Your role does not include submitting a DDS yourself. 

Your obligations do include collecting and storing the DDS reference numbers your suppliers provide, maintaining traceability so that products can be linked back to upstream due diligence, keeping the relevant records for at least five years, and being able to respond to checks from national competent authorities. 

For first operators, meaning companies that import commodities or are the first to place them on the EU market, the picture is different. The due diligence obligation sits entirely with you. Your supplier’s job is to give you the data you need: geolocation coordinates, chain of custody information, legality documentation. Conducting the actual risk assessment, mitigating identified risks, and submitting the DDS is your responsibility. 

In both cases, “my supplier handles it” captures at best half the picture. The question is not whether your supplier has obligations. It is whether you understand yours. 

Assumption 3: “I have until 2027, so I can wait” 

Of the three assumptions, this one carries the highest operational risk. 

The June 2027 deadline for small and micro companies is a legal compliance date, not an operational start date. The activities that lead to compliance take time, and none of them happen in parallel. 

Supplier outreach alone frequently takes longer than companies expect. Smaller producers in high-risk or standard-risk regions may not have previously been asked for GPS coordinates or chain of custody data in a structured format. Getting that data collected, validated, and formatted correctly is a process that runs in months, not weeks. 

Companies that begin in 2027 face a compounded problem: given typical procurement lead times, orders placed in early 2027 may arrive at customs after the June deadline. Without compliant documentation in place, those shipments risk being held at the border turning a compliance issue into an immediate operational disruption. 

Starting now, even at a modest pace, closes that gap. Identifying your scope and your role, beginning supplier conversations, and evaluating tooling options are all steps that can be taken today without committing to a full implementation. 

Getting started without enterprise complexity 

For SMEs approaching EUDR for the first time, the goal is not to build a separate compliance function overnight. It is to integrate the regulation into your existing procurement and supply chain operations: clarity on scope and role, a supplier data collection process that actually works, and a system that handles the heavy lifting without requiring a dedicated compliance team. osapiens EASY START for EUDR is designed specifically for that starting point, covering all EUDR obligations for importers and traders with guided workflows and a free supplier portal.