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As the European Union Deforestation Regulation (EUDR) evolves, the introduction of Micro or Small Primary Operators (MSPOs) has raised important questions for both suppliers and downstream companies. While the category aims to simplify compliance for smaller operators, it also introduces new considerations for traceability, risk, and accountability.
A Micro or Small Primary Operator (MSPO) is a newly defined category under EUDR for smaller operators who place or export products they have grown, harvested, or produced themselves.
To qualify, an operator must:
This category is designed to reduce the compliance burden for smaller, low-risk producers.
The primary goal is proportionality.
Not all operators pose the same level of deforestation risk. By introducing MSPOs, the regulation aims to:
However, simplification for one group doesn’t eliminate responsibility across the supply chain.
Yes, but with simplified obligations.
Even though MSPOs may face reduced due diligence requirements, they must still ensure that:
In short, compliance is not removed it is adapted.
Not necessarily.
This is a common misconception.
While MSPOs operate in low-risk countries, downstream companies (like manufacturers or importers) are still responsible for ensuring:
If MSPO data is incomplete or unverified, the risk shifts downstream.
Despite simplifications, several challenges remain:
In practice, MSPOs can introduce hidden compliance risks if not managed properly.
Companies should treat MSPO sourcing with the same rigor as other suppliers, by:
The key is not to assume compliance but to validate it continuously.
Digital traceability platforms play a critical role in bridging gaps by:
This helps companies maintain compliance without increasing manual effort.
No. MSPO refers to the size and nature of the operator, while low-risk classification refers to the country’s deforestation risk level.
MSPO obligations may differ, but downstream operators often still need to ensure that a valid DDS or equivalent compliance documentation exists.
No. Traceability remains essential, especially for companies sourcing from MSPOs to ensure compliance with Article 3 requirements.
No. While obligations may be simplified, non-compliance can still lead to penalties depending on the role and responsibilities in the supply chain.
The introduction of MSPOs is a step toward making EUDR more practical and inclusive.
But it doesn’t remove the need for robust traceability and verification.
For companies, the real challenge is not identifying MSPOs it’s ensuring that sourcing from them remains compliant, transparent, and defensible.
Because under EUDR, accountability doesn’t stop at the supplier.
It flows across the entire supply chain.