When does my business count as a small or micro-enterprise under the EUDR?

SME status depends on the standard EU definition of company size

Your company qualifies as a micro, small or medium-sized enterprise under the EUDR when it meets the definition of micro, small and medium-sized enterprises that is also used elsewhere in EU law. That definition does not look at the sector in which you operate — coffee, timber, rubber, or anything else — but at the size of the enterprise itself, measured according to criteria such as the number of employees, annual turnover and balance sheet total. An enterprise that remains below the standard thresholds on those points falls under the EUDR regime for small or micro-enterprises.

This classification is not merely a label: it co-determines which obligations apply and, more importantly, when they take effect. The regulation has four different dates of application, which depend on the combination of your role in the supply chain — economic operator or trader — and the product you import or market. Whether you qualify as an SME is one of the factors that plays a part in determining which date and which lighter or heavier obligation applies to your enterprise. Anyone in doubt about their own size is well advised to compare their own annual figures against the official definition, preferably using the most recent year-end as the starting point.

What this is based on: Article 2 and the 2025 amendments

The definition of SMEs is set out in the definitions section of Article 2 of Regulation (EU) 2023/1115, which refers to the existing EU-wide classification of enterprise size. Regulation (EU) 2025/2650 subsequently adjusted, among other things, the timetable and the treatment of smaller economic operators, which has a direct impact on the question of when an SME must start complying. For the precise threshold values and the exact wording of the definition, the full text of the regulation on EUR-Lex is the reliable source.