June 2026

Following the European Commission's December 2025 amendments to introduce targeted simplifications to the EUDR, additional documentation was published at the end of April 2026. This updated framework provides significant relief by reducing requirements throughout the value chain.

What is now officially confirmed:

EUDR timeline:

• Medium-sized and large companies (all products): The EUDR applies from Dec. 30, 2026.
• Micro and small enterprise companies (paper products): The EUDR applies from Dec. 30, 2026.
• Micro and small enterprise companies (cacao, coffee, palm oil, cattle, rubber and soy products): The EUDR applies from June 30, 2027.

Simplified due diligence requirements

The 2026 EUDR documentation confirms that due diligence remains the responsibility of first operators — the companies that first place relevant products on the EU market. As a result, data management requirements throughout the value chain are being streamlined.

For products supplied by Avery Dennison, due diligence will already have been conducted upstream where required. Downstream operators are generally not required to conduct new due diligence or submit additional due diligence statements (DDS) for these products. Accordingly, Avery Dennison will provide DDS reference numbers for transactions where we act as first operator.

Reference number management
Avery Dennison will send you valid DDS reference numbers for all applicable product lines as and when they are required.

Important: While your obligations related to EUDR due diligence information and DDS reference numbers provided by Avery Dennison have been greatly reduced, you remain responsible for certain EUDR requirements, including, for example:

• Registration within the European Commission’s official digital registry (TRACES)
• Collection and retention of supplier and customer information