The Commission's EUDR FAQ: which version applies, what version 5 answers anew and what changed in August 2026

As at 29 September 2026.

The Commission's questions and answers are the document almost everyone in EUDR practice relies on: authorities, associations, consultants and software providers. It now runs to more than 90 pages, keeps appearing in new versions and is not binding. This article explains which version applies, which new answers really matter for companies and what changed most recently.

In brief

• Version 5 is current. It is titled "April 2026"; the Commission published a revised version in August 2026. A German translation is available on the Commission's CIRCABC platform.
• Not binding. According to its own disclaimer, the FAQ only reflects the views of the Commission services. The Regulation (EU) 2023/1115 and its implementing acts prevail.
• Almost 100 answers are new or updated. Compared with the fourth version of April 2025, version 5 flags every new or updated question.
• The key change in August concerns FAQ 3.1.1. Any change of the commodity code makes a processor a downstream operator, not only a change of the digits listed in Annex I.
• New focus areas: the three roles and their obligations after the amendment of December 2025, micro and small primary operators, online sales, export and re-import, substantiated concerns and the 2020 forest type map.

Which version applies

The Commission publishes the FAQ on its page on implementing the Regulation. The current file there is "Frequently Asked Questions – April 2026", published on 21 August 2026. In substance this is version 5 in a revised form: it has the same title as the April version, and only this file is listed on the page. The German translation is on CIRCABC, the Commission's document platform, dated 20 August 2026.

Older versions are out of date. This is not a formality: several answers in the fourth version predate the amending Regulation (EU) 2025/2650 of December 2025 and contradict the current position. Anyone citing the FAQ in supplier correspondence or an audit file should state the version and the question number.

The FAQ is not binding. According to its disclaimer, it is a working document of the Commission services, "not legally binding", and does not engage the Commission's liability. In practice it is still the most important yardstick, because national authorities know it and it shows how the Commission reads the Regulation. How it fits together with the Regulation, guidelines and implementing acts is shown in the overview of the current EUDR status.

What changed in August 2026

We compared the April and August versions sentence by sentence. In substance, two passages changed.

FAQ 3.1.1: any new commodity code counts. Until now, a change of the commodity code only made a processor a downstream operator if it affected the digits listed in Annex I. The Commission's example was the roaster: green coffee and roasted coffee both start with 0901, so the roaster remained a trader. In the new version, any change of the HS or CN code is enough. In the same example the roaster is now a downstream operator; only someone reselling green coffee without a change of commodity code remains a trader. This affects processing steps where the four-digit heading stays the same, such as roasting coffee or refining palm oil. What follows in practice is shown in the article on coffee and cocoa and the article on palm oil.

FAQ 3.7: export removed from an exception. The answer on Article 7 deals with non-EU operators and the first company in the EU that takes over their goods. That company has no obligations under Article 7 if it does not place the product on the market or make it available. Until now the text added "or exports them"; this has been removed. Exports are dealt with elsewhere in the FAQ (5.6.1, see below).

In addition, FAQ 4.9 on planting trees for restoration is newly flagged as updated, without any substantive change we could find; the rest is wording and page breaks.

The most important new answers in version 5

Roles and obligations after the December 2025 amendment

Three roles (FAQ 3.1). The FAQ distinguishes operators, downstream operators and traders. Micro and small primary operators are a subgroup of operators with simplified obligations.

What downstream actors must do (FAQ 3.4). Downstream operators and traders collect details of their direct business partners: name, trade name or trade mark, postal address, email address and, where available, web address, for both suppliers and customers. They may only make goods available once they have these details. Only those buying directly from an operator also need the operator's reference numbers. Since the amendment, downstream actors no longer have a due diligence obligation of their own.

Who the first downstream actor is (FAQ 3.5). It is whoever buys directly from an operator. The operator must pass on its reference numbers on its own initiative (Article 4(7)). Anyone who receives no numbers may assume in good faith that its supplier is not an operator and does not have to check. The exception is where it knows the supplier is an operator withholding the numbers; then it must not make the goods available.

Verification numbers (FAQ 3.6.1). Reference numbers only go to direct customers that are downstream operators or traders, not to consumers or to manufacturers of products outside Annex I. The Regulation does not require the verification number to be passed on. How reference and verification numbers relate is explained in the article on the reference number.

Both roles in one company (FAQ 3.8). A company importing roundwood and making sawn timber from it is an operator for the import and the first downstream operator for the sawn timber. It already holds the reference numbers itself.

The roles are explained in detail in the article on traders and operators.

Micro and small primary operators

Four conditions (FAQ 3.21). A micro or small primary operator is a natural person or a micro or small undertaking under the Accounting Directive, established in a low-risk country, placing on the EU market or exporting directly and having produced the products itself in its country of establishment. Producers outside the EU who supply intermediaries outside the EU have no obligations under the Regulation.

Address instead of geodata (FAQ 3.28). Micro and small primary operators may state their postal address if it corresponds to the location of the plot or establishment. A purely administrative seat is not enough.

Cooperatives (FAQ 3.20). A cooperative can submit a declaration in its own name if it places products on the market itself, or as authorised representative of its members if it is established in the EU.

Online sales, export and re-import

Online sales (FAQ 3.17 to 3.19). The Regulation applies to online and distance sales like any other channel, B2B and B2C. A consumer is never an operator, even if named as importer in the customs declaration; the operator is whoever actually supplies the goods.

Export (FAQ 5.6.1). Exporters are operators or downstream operators. Downstream exporters do not give a reference number at export but use a dedicated TARIC code (Article 26(4)). The codes are listed in the glossary of EUDR TARIC codes.

Re-import (FAQ 5.4). An importer is in principle an operator. Only someone who can show that the goods were previously placed on the EU market and then exported counts as a downstream operator on re-import. The FAQ mentions customs declarations, contracts and transport documents as evidence. Details are in the article on export and re-import.

Authorities, evidence and tools

Substantiated concerns (FAQ 4.15). Anyone can raise them with an authority or directly with a company. They must be duly reasoned and based on objective and verifiable information. A company receiving one must inform the authority.

Forest type map 2020 (FAQ 9.10.5). The Commission provides a global map of forest types at the cut-off date of 31 December 2020 at ten-metre resolution: primary forest, naturally regenerating forest and planted forest. It is not binding but an obvious first source for the risk assessment. What supplier geodata must look like is explained in the article on geodata.

Cattle (FAQ 1.26). Whoever first places cattle on the market is an operator; a fattening farm reselling the same animals is a trader; whoever makes meat from them is a downstream operator.

Fines (FAQ 10.2). For legal persons the maximum must be at least four per cent of EU-wide annual turnover.

How to work with the FAQ

1. Record version and number. In the audit file and in supplier letters, always write "FAQ version 5, August 2026 revision, question 3.1.1" rather than just "according to the FAQ".
2. Check against the Regulation. Where the FAQ seems to depart from the Regulation, the Regulation prevails.
3. Watch for new versions. The Commission revises the FAQ regularly. Before important decisions, check whether a new version has appeared.
4. Read national guidance too. In Germany, the Federal Office for Agriculture and Food (BLE) answers questions on national implementation on its website.

Which role you hold per product is what the EUDR check settles. The overall picture is in the EUDR guide.

Frequently asked questions

Is the Commission's EUDR FAQ binding?

No. According to its disclaimer, it only reflects the views of the Commission services, is not legally binding and does not engage the Commission's liability. Regulation (EU) 2023/1115 as amended and its implementing acts prevail.

Is the EUDR FAQ available in other languages?

Yes. The Commission provides a German translation of version 5 on its document platform CIRCABC, dated 20 August 2026. The Commission's page links to the English version.

Which version of the EUDR FAQ is current?

Version 5, titled "April 2026", in the revised version of August 2026. Earlier versions, including the fourth of April 2025, are out of date.

What changed in FAQ 3.1.1?

Since August 2026, any change of the HS or CN code makes a processor a downstream operator. Before, only the digits listed in Annex I counted. A coffee roaster is therefore now a downstream operator rather than a trader.

Where can I find national guidance?

National competent authorities publish their own guidance; in Germany this is the Federal Office for Agriculture and Food (BLE). It supplements the Commission's FAQ but does not replace it.

Sources and status: Commission FAQ "Implementation of the EU Deforestation Regulation – Frequently Asked Questions", version 5 (April 2026), April and August 2026 versions, in particular questions 1.26, 3.1, 3.1.1, 3.4, 3.5, 3.6.1, 3.7, 3.8, 3.17 to 3.21, 3.28, 4.15, 5.4, 5.6.1, 9.10.5 and 10.2; German translation on CIRCABC (20 August 2026). Regulation (EU) 2023/1115 as amended by Regulation (EU) 2025/2650, Articles 4, 5, 7 and 26. As at 29 September 2026. This article is not legal advice.

Photo: Vardan Papikyan via Unsplash.