EC moves to ease EUDR compliance burden with new DDS guidance on 'upstream' and 'downstream' actors

As part of the evolving implementation of the EU Regulation on Deforestation-free Products (EUDR), CocoaRadar understands the latest (third) edition of the Commission’s supply chain guidance – updated following targeted amendments adopted in late 2025 – signals a clear shift: compliance responsibilities are being streamlined toward those placing goods on the EU market for the first time, while duplication across the value chain is reduced.

A Shift in Responsibility Across The Supply Chain

At the core of the update is a sharper distinction between 'upstream' and 'downstream' actors.

Upstream operators – importers, producers, and exporters placing commodities such as cocoa, soy, palm oil, and timber on the EU market – remain fully responsible for due diligence. This includes verifying that products are deforestation-free, legally produced, and covered by a valid DDS before market entry.

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By contrast, downstream operators and traders are no longer required to submit DDS. Instead, their obligations focus on traceability: collecting, storing, and, where necessary, verifying DDS reference numbers generated upstream.

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