EUDR deadlines for SMEs: do I have until 30 June 2027?

Short answer: only if your company is a micro or small enterprise, was already one on 31 December 2024 and acts as an operator with a product that was not listed in the annex of the former EU Timber Regulation (EUTR). In that case the EUDR applies to you from 30 June 2027. Medium-sized and large companies apply it from 30 December 2026, as do micro and small enterprises placing on the market wood, pulp, paper or furniture listed in the EUTR annex. Size is measured company by company, not at group level.

Which date applies to me?

Your case	Date of application	Basis
Large company	30-12-2026	Art. 38(2)
Medium-sized company	30-12-2026	Art. 38(2)
Micro or small enterprise established as such by 31-12-2024 at the latest, product outside the EUTR annex	30-06-2027	Art. 38(3)
Micro or small enterprise with a product in the EUTR annex (logs, sawn wood, panels, pulp, paper, wooden furniture 9403…)	30-12-2026	Arts. 37 and 38(3)
Micro or small enterprise established in 2025 or later	30-12-2026	Art. 38(3); FAQ 3.10

Source: Art. 38 of Regulation (EU) 2023/1115, as worded by Regulation (EU) 2025/2650. There is no proposal for a further postponement, and no grace period: the one proposed by the Commission was removed by Parliament and Council in 2025.

Why do medium-sized companies get no extension?

Because the Regulation uses two different concepts and they are easy to confuse:

"SME" (Art. 2(30)) covers micro, small and medium-sized enterprises. It is used to lighten obligations: SMEs need no compliance officer, independent audit or annual public report, and SME downstream operators and traders do not register in the system.
The extension to 30 June 2027 (Art. 38(3)) only mentions natural persons, micro enterprises and small enterprises.

Result: a medium-sized company is an SME for the purpose of obligations, but applies the Regulation from 30 December 2026.

Why does timber from the former EUTR get no extension?

Regulation (EU) No 995/2010 (EUTR) is repealed on 30 December 2026 (Art. 37(1)). If its products had an extension, they would go unregulated for six months. That is why Art. 38(3) expressly excludes them. What matters is the CN code of the product, not the sector:

In the EUTR annex: 30-12-2026 for everyone	Outside the EUTR annex: extension possible
4401, 4403, 4406 to 4416, 4418; pulp and paper of Chapters 47 and 48 (except bamboo-based and recovered products); wooden furniture 9403 30, 9403 40, 9403 50 00, 9403 60 and 9403 90 30 (now 9403 91, parts of wood); prefabricated buildings 9406 00 20	4402 (wood charcoal), 4404, 4405, 4417, 4419, 4420, 4421 and seats 9401

Source: annex to Regulation (EU) No 995/2010. Note: wooden furniture was in the EUTR, so a micro or small enterprise placing it on the market applies the Regulation from 30 December 2026. And the EUTR remains in force until that date: anyone placing timber from its annex on the market today already has obligations.

How is my company's size measured?

Under Accounting Directive 2013/34/EU, not the 2003 SME Recommendation used for state aid (Art. 2(30); FAQ 3.10).
Company by company: what counts is the balance sheet, turnover and headcount of each company, "not of the group as a whole" (FAQ 3.13). A small subsidiary of a large group can be a small enterprise for EUDR purposes.
Two out of three thresholds: to be small, a company must stay within at least two of these three limits: 50 employees, EUR 10 million turnover and EUR 5 million balance sheet total. To be micro: 10 employees, EUR 900,000 turnover and EUR 450,000 balance sheet total (Art. 3 of Directive 2013/34/EU, with the amounts set by Commission Delegated Directive (EU) 2023/2775).
National thresholds do not count: the Directive's thresholds apply, not those set by the national laws transposing it (FAQ 3.25).
Key date for the extension: having been micro or small on 31 December 2024, under the thresholds in force on that day (FAQ 3.10).
Changes in size: a company only changes category after exceeding, or ceasing to exceed, two of the three thresholds for two consecutive financial years (FAQ 3.24).

Each company also needs its own account in the EUDR Information System: there is no group account, although one group company can act as authorised representative for the others (FAQ 3.13).

Does the extension apply to traders and downstream operators?

Art. 38(3) refers to operators. According to the Commission Guidance C/2026/3896 (section 3), what decides whether a trader or downstream operator has obligations is when the product was placed on the market: if a micro or small operator placed it on the market within its transitional period, the exemption also extends to those who make it available afterwards. A micro or small trader has no extension of its own: if the product was placed on the market by a medium-sized or large company from 30 December 2026, the trader's obligations start on that day.

What simplified obligations do micro and small enterprises have?

It depends on their role. The big simplification, the simplified declaration, is not for every micro or small enterprise:

Case	What it must do
Micro or small primary operator: a producer established in a low-risk country (such as Spain) selling what it produces itself	A single simplified declaration with the estimated annual quantity, instead of one statement per shipment. It can use the postal address instead of geolocation (Arts. 4a and 2(15a); Annex III)
Micro or small importer	Full due diligence and due diligence statement, like any operator, from its date of application. No compliance officer, no independent audit and no public report (Arts. 11(2) and 12(3))
Micro or small enterprise as downstream operator or trader	Collect and keep for 5 years the details of suppliers and customers. It does not register in the system and does not have to carry out checks in the case of substantiated concerns (Art. 5)
Operator that is a natural person or micro enterprise	May ask its downstream operator or trader customer, if that customer is not a natural person or micro enterprise, to submit the statement on its behalf as authorised representative (Art. 6(3))

At customs, until 29 June 2027, a micro or small importer covered by the extension can use the TARIC exemption Y141, which is not valid for products in the EUTR annex (DG TAXUD's Revision 1 of the TARIC document, 23-9-2026).

Frequently asked questions

My company has 120 employees. Do I have until June 2027?

No. With more than 50 employees you are not a small enterprise, unless you stay below the other two thresholds. A medium-sized company applies the Regulation from 30 December 2026.

We are small but we make wooden furniture. Which date applies to us?

30 December 2026 for the 9403 codes that were in the EUTR annex. Check the CN code of each product.

We are a small subsidiary of a multinational group. Do we count as a large company?

No. Under the EUDR each company is measured separately (FAQ 3.13).

My company was set up in March 2025 and is a micro enterprise. Do I get the extension?

No. The extension requires having been established as a micro or small enterprise by 31 December 2024 at the latest.

My customers are large companies. Does their deadline affect me?

In practice, yes: a customer that applies the Regulation from 30 December 2026 will ask you for the data by that date.

Keep reading: what is the EUDR: the complete guide · how much are the EUDR fines?.

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