Simplification of EU Deforestation Regulation: Scope and due diligence for lessors

On 4 May 2026, the European Commission published a package on the simplification of the EU Deforestation Regulation (EUDR) ahead of its entry into application by end of this year (30 December 2026). The package presented includes a report on the simplification measures implemented since the entry into force of the EUDR in June 2023, an updated guidance document, updated FAQs, as well as a draft delegated act which incorporates targeted amendments to the EUDR product scope. 

As background, the EU Deforestation Regulation aims to ensure that key goods placed on the EU market do not contribute to deforestation and forest degradation. EUDR is linked to the production of seven commodities covered by the regulation: cattle, wood, cocoa, soy, palm oil, coffee, rubber, and some of their derived products. Under the EUDR, any operator or trader who places or makes these commodities available on the EU market, or exports from it, must be able to prove that the products do not originate from recently deforested land or have contributed to forest degradation by complying with specific due diligence obligations.

In December 2025, the European Parliament and Council adopted the revised text of the EUDR which postponed the application date. Following the revision, EUDR applies from 30 December 2026 for large and medium companies, and from 30 June 2027 for micro and small enterprises.

The updated Commission guidance, FAQs and the draft delegated act confirm part of what Leaseurope had requested. First, that the guidance according to which products rented out are not considered to be placed or made available on the market, also covers products leased under a leasing contract where there is no transfer of ownership. Second, that used and second-hand products fall outside the scope of the EUDR, including retreaded tyres. 

However, Leaseurope is calling on the Commission for another clarification, key for the leasing industry. Leasing companies, when offering purely asset finance services to support the activities of manufacturers, should not be considered “traders” (that make products available on the market) for the purposes of the EUDR. 

As it currently stands, lessors are considered traders when they make products already placed on the Union market available. Traders are not required to carry out due diligence or submit due diligence statements (DDS), except when they import products not covered by a due diligence statement. Nonetheless, traders are required to register in the Information System, prior to making products available on the market, and to collect and keep certain information  such as the existing DDS reference numbers of the products. . Subsequent downstream operators or traders (not the first ones) are required to collect and keep only basic information (e.g. details of their suppliers and of downstream operators and traders to whom they have supplied relevant products). 

Leaseurope will keep raising awareness on this issue and explaining that in the case of providing pure financing, the lessors are not part of the value chain.