21.1 The simplification review (Article 34(1a)) — completed
Discharged by report COM(2026) 191 of 04/05/2026. Its central conclusions: a reduction of around 75% in annual compliance costs; no new proposal to amend the basic text; and a package of non-legislative measures — a new Guidance Document and FAQ, a delegated act on Annex I, an implementing regulation on the system, repositories of legislation and of certification schemes, and improvements to the Information System (API, grouping of references, geolocation processing, service accounts).
21.2 The general review (Article 34(2)) — by 30/06/2030
The first general review is to assess, on the basis of specific studies:
| Point | Topic | Relevance to the grain chain |
|---|---|---|
| (a) | Additional trade facilitation tools for least developed countries and for standard- or high-risk countries | Medium |
| (b) | The impact on farmers, smallholders in particular, on indigenous peoples and on local communities | High |
| (c) | Broadening the definition of forest degradation | Low (wood) |
| (d) | The 4 ha threshold for mandatory use of polygons | High |
| (e) | Changes in trade flows pointing to circumvention | Medium |
| (f) | The effectiveness of checks | Medium |
| (g) | Including other wooded land and setting its cut-off date | Very high — it would reach open formations of the Cerrado |
| (h) | Including other natural ecosystems (grasslands, peatlands, wetlands) | Very high — the Pampa, the Pantanal, Cerrado grasslands |
| (i) | Including other commodities, maize among them, and products such as biofuels (HS 3826) | Very high — maize and biodiesel |
| (j) | The role of financial institutions | High — rural credit and export finance |
| (k) | The role of downstream operators and traders | Medium |
| (l) | The role of MSPOs and the risk of circumvention | Low while Brazil is not low risk |
Later reviews follow every five years. Annex I may be amended by delegated act as regards the CN codes (Article 34(1)), under a delegation running for five years from 29/06/2023 and tacitly renewable (Article 35).