The European Commission’s October 2025 EUDR proposal introduces a targeted exemption for this specific group. Micro and small primary operators are no longer required to submit a due diligence statement, but only if all of the following apply:
→ The operator qualifies as a natural person or a micro- or small-sized undertaking
→ They are based in a country officially classified as low risk under the EU benchmarking system
→ They are the primary producer of the commodity, meaning that they grow, harvest, obtain from or raise the relevant commodities in the relevant products themselves
What stays the same?
Traceability requirements across the supply chain. Larger downstream operators and traders must still collect and pass on reference numbers to ensure an unbroken compliance chain.
Why this matters
The exemption reduces the compliance burden for small-scale producers in low-risk areas,without weakening traceability standards or supply chain accountability.
