EUDR · Simplification Package · COM(2026) 191 final
The Simplification Package, decoded.
On 4 May 2026, the European Commission adopted COM(2026) 191 final — the Simplification Package. It changes how operators and cooperatives file compliance data, not whether they have to. Here is what actually shifted, and what didn't.
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UPDATED · 15 Jul 2026
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What changed
The 75% cost reduction — where it comes from
The Commission's own impact assessment attributes an estimated 75% reduction in compliance cost for repeat filers to four mechanical changes in how due diligence data gets submitted and reused — not to any relaxation of what has to be proven.
-75%
Estimated compliance cost reduction for repeat filers
01
Grouped filing replaces per-shipment individual Due Diligence Statements with one statement per consolidated lot.
02
Reusable geolocation records mean a verified plot doesn't need full resubmission every season — only periodic revalidation.
03
Simplified declarations for micro and small primary operators cut the data fields required relative to a full DDS.
04
Removal of duplicate downstream checks when a valid upstream DDS reference number already exists for the same volume.
Who you are now
New operator categories, and what they mean
The Package sharpens the line between operator categories. Your obligation level is now determined more precisely by which category you fall into — which makes getting your classification right the first real decision to make.
| Category | What it means for you |
|---|
| Large / Medium Operator |
Full due diligence obligations unchanged — geolocation, legality, risk assessment, individual or grouped DDS filing, no simplified-declaration eligibility. |
| Micro / Small Primary Operator |
Eligible for the new simplified declaration route, subject to the same underlying geolocation and legality evidence. |
| Cooperative-Aggregated First Placement |
A new sub-category recognizing that a cooperative, not each individual member-producer, is the entity placing goods on the market — the basis for group filing. |
| Trader (SME vs non-SME) |
SME traders retain lighter-touch obligations; non-SME traders carry the same due diligence responsibility as before. |
Group filing
The cooperative grouping provision
Cooperatives and unions can now file a single Due Diligence Statement covering a consolidated export lot, rather than a separate statement traceable to each individual member-producer submission. For a union aggregating hundreds of smallholder plots, this is the single largest administrative relief in the Package.
What the headline coverage leaves out
The EU-representative requirement
Group filing under the Package requires the cooperative to designate an EU-based authorized representative — a legal entity within the EU that holds accountability for the group filing in dealings with EU authorities. Most African cooperative structures do not currently have this relationship in place, and establishing one is not covered by the cost-reduction figure above.
Lighter paperwork
The simplified declaration for micro and small primary operators
Operators that qualify as micro or small primary operators can file a reduced-field declaration in place of the full Due Diligence Statement. The declaration still draws on the same underlying geolocation and legality evidence — it is a lighter submission format, not a lighter evidence standard. A cooperative filing on behalf of qualifying members still needs the full plot-level dataset behind the simplified form.
Optional, not mandatory
Voluntary DDS grouping — how it works
Grouping is opt-in. An operator that prefers to file individually for every shipment can still do so — nothing forces consolidation.
01
Opt in by designating a group filing arrangement, naming the responsible entity and, where applicable, the EU-based representative.
02
Consolidate shipments within a defined period and volume cap under a single DDS reference number.
03
Maintain member-level records even though the filing is grouped — a single flagged plot inside a group filing can still put the whole lot at risk.
04
Revert to individual filing at any time if the grouping conditions stop being met or the arrangement stops making sense.
What did not change
Do not read simplification as relaxation
-
FIRM
The December 30, 2026 large-operator deadline has not moved under this Package. Simplification changes the process between now and then, not the date itself.
-
UNCHANGED
All countries remain in the standard-risk benchmark tier. The Package does not touch country benchmarking — there is still no country-based shortcut.
-
UNCHANGED
The geolocation requirement is untouched — polygon data for plots over 4 hectares, point data below that, checked against the December 31, 2020 cut-off. Group filing changes who submits it, not whether it exists.
-
UNCHANGED
Liability still sits with the operator placing goods on the EU market. A cooperative's group filing — and its EU representative — is a data-aggregation and accountability layer, not a liability shield.
The MIDIR signal
The one thing nobody is publishing for African exporters
Every summary of this Package leads with the 75% cost-reduction figure. Almost none of them lead with what it costs to unlock it.
MIDIR SIGNAL · EU-REPRESENTATIVE GAP
The savings are theoretical until a cooperative closes the representative gap.
Group filing — the single biggest driver of the cost reduction — is gated behind an EU-based authorized representative requirement that almost no West or Central African cooperative currently has in place. Until that relationship exists, a union defaults back to individual, non-grouped filing at full administrative cost, regardless of what the headline figure promises. This is the gap between the Package's advertised savings and what's actually available to a cooperative today — and it's the first thing MIDIR checks in any cooperative-level assessment.