THE RADAR
CBAM's first price tag lands
The Commission published the Q1 2026 CBAM certificate price at €75.36/tCO₂e on April 7 — the first concrete cost benchmark under Regulation (EU) 2023/956's definitive phase. Importers of covered goods can now model landed-cost exposure for Q1 shipments ahead of February 2027 certificate purchases. Plug this number into your accruals before Q2 pricing on July 6. [Finance]
EUDR Information System nears reopening
The system under Article 33 of Regulation (EU) 2023/1115, offline since February 16, is expected to announce a reopening date this week. Operators who have not registered face roughly 8 months before the December 30, 2026 enforcement date. Treat the reopening as day one — register and test your DDS submission workflow immediately. [Compliance / Trade Ops]
Omnibus I reshapes CSRD and CSDDD
Directive (EU) 2026/470, in force since March 18, narrows CSRD to companies exceeding 1,000 employees and €450M turnover, eliminates Wave 3 for listed SMEs, and pushes CSDDD transposition to July 26, 2028 with fines capped at 3% of worldwide net revenue. If your company fell out of CSRD scope, reassess whether voluntary VSME reporting still serves your due-diligence data needs. [Sustainability Reporting / Legal]
DEEP DIVE: What the April 30 Simplification Review Means for Operators
The Commission has until April 30 to deliver its EUDR simplification review under new Article 34(1a), accompanied by a report to Parliament and Council and, where appropriate, a legislative proposal. For operators building compliance systems against a December 30 enforcement date: should you pause, adjust, or press ahead?
What may change
The review is expected to address Annex I product scope — instant coffee and palm-oil soap have been flagged as potential additions, alongside clarifications on exemptions for waste, samples, and packaging. A revised draft Delegated Act amending Annex I, first circulated for public feedback in May 2025, is expected as part of the package. The Commission will also amend the Implementing Regulation on the Information System. The country benchmarking review has been postponed indefinitely according to the 39th EUDR Expert Group meeting readout (February 10, 2026). The May 2025 classification under Implementing Regulation (EU) 2025/1093 stands.
What will not change
The core due diligence framework under Articles 8–11 is settled law. Procedure 2025/0329(COD) is fully closed — no active co-legislator rewrite of core operator duties is open, though the April 30 review can still trigger delegated acts, implementing acts, and a legislative proposal. The December 30, 2026 application date is not on the table. Brazil, Indonesia, and Côte d'Ivoire remain at standard risk, meaning full due diligence — not simplified under Article 13 — is required for the origins dominating EU soy, palm oil, and cocoa imports.
One nuance for low-risk origins: new Article 4a(5) allows micro or small primary operators in low-risk countries to replace geolocation with the postal address of their plots or establishments. If you source timber from the US or soy from Canada — both low risk — this reduces the data burden on upstream suppliers. It does not apply to standard-risk origins.
What to do now
Do not wait. Geolocation data collection, supplier mapping, and Information System registration will take months regardless of whether the Commission adjusts Annex I. Any scope changes arrive as a delegated act with a scrutiny period of up to four months, pushing effective dates past December 30. Run a gap analysis on your top 10 supply chains against Articles 9 and 10 this month. If your suppliers cannot provide geolocation as defined in Article 2(28) — polygon coordinates for plots exceeding 4 hectares, or a single point with six decimal digits for smaller plots — that is the bottleneck to solve now, not after the review lands.
COMPLIANCE CALENDAR
Mid-April 2026 — EUDR Information System reopening date to be announced — see Radar above. [Compliance / Trade Ops]
April 30, 2026 — Commission delivers EUDR simplification review under Article 34(1a) — see Deep Dive. [Legal / Compliance]
July 6, 2026 — Q2 2026 CBAM certificate price published — update landed-cost models. [Finance / Procurement]
September 18, 2026 — Commission deadline to adopt simplified ESRS delegated act under Omnibus I. [Sustainability Reporting]
December 30, 2026 — EUDR enforcement begins for operators and non-SME downstream operators and traders. Former EUTR (Regulation 995/2010) products have NO SME grace period — enforcement starts this date for all timber operators regardless of size. EUTR is repealed but continues to apply until December 31, 2029 for timber produced before June 29, 2023. [Compliance / Trade Ops / Legal]
February 2027 — CBAM certificate purchase window opens — importers buy certificates for all 2026 shipments. [Finance / Customs]
June 30, 2027 — EUDR applies to operators that are natural persons or micro/small undertakings established by December 31, 2024. Does NOT apply to former EUTR products — see December 30, 2026 entry. [Compliance]
TOOL RADAR: Sourcemap
Sourcemap is a supply chain mapping and traceability platform used by food, agriculture, and consumer goods companies to visualise multi-tier supplier networks from origin to finished product. The platform maps over 6 million suppliers across 250+ brands. For EUDR-exposed operators, Sourcemap offers automated plot-level geolocation data collection, satellite-based deforestation screening, and direct integration with the EUDR Information System for DDS submission — addressing the Article 9 information requirements most compliance teams flag as their primary bottleneck. The platform connects to SAP ERP, triggering DDS workflows automatically from purchase orders.
Before booking a demo, ask about: API documentation and bulk upload support; DDS reference number handling for mixed-lot consignments; audit trail export for competent authority inspections; and proof of live EUDR Information System integration.
Editorial note: Sourcemap is not a current Green Gate sponsor.
TARIK'S DESK VIEW
A launch editorial from the founder
Somewhere in a Geneva trading house right now, a compliance officer is staring at a spreadsheet containing the latitude and longitude coordinates of a cocoa farm in Côte d'Ivoire, expressed to six decimal digits. This person can pinpoint a cacao tree to the width of a dinner plate but cannot tell you whether the Information System they need to upload this data into will be online next week. The system has been down since February 16. It's mid-April. The enforcement deadline is December 30. This is fine.
I started The Green Gate because the answer to "what actually changed this week?" always required stitching together Commission press releases, Official Journal publications, law firm alerts, and the occasional cryptic LinkedIn post from someone who attended an Expert Group meeting. No single publication did this. So now one does. Every Wednesday: three developments that matter, one deep dive, the compliance dates you need to track, one tool worth knowing about. Four minutes. Practitioner-grade.
The European Green Deal is not one regulation. It is at least five major instruments — EUDR, CSRD, CSDDD, CBAM, CRCF — deployed simultaneously and interacting in ways that no single acronym captures. Omnibus I did not reduce this complexity. It redistributed it. CSRD's scope shrank; CSDDD's transposition got pushed to 2028. But EUDR's core obligations are untouched — enforced at the product level, the shipment level, the customs clearance level. The compliance challenge has migrated from annual corporate reports to per-consignment due diligence statements. The companies that will be ready by December 30 are the ones treating EUDR as a data engineering challenge, not a paperwork exercise.
Competent authorities across 27 Member States must inspect 3% of operators for standard-risk products, 9% for high-risk origins, 1% for low-risk. Fines under Article 25(2)(a) must be set at a minimum maximum of at least 4% of total annual Union-wide turnover — and Member States may set penalties above that floor. Monitor national transposition in your key markets. If you hold FSC, RSPO, or Rainforest Alliance certification and believe you are covered: you are not. Under Article 10(2)(n), certification provides "complementary information" for risk assessment. It does not substitute for due diligence under Articles 8 through 11.
Before Friday: confirm your EUDR Information System credentials are active, classify your top 10 origins by their current benchmark status, and identify which suppliers still cannot provide plot-level geolocation — or qualify for the Article 4a postal-address simplification. That's your starting position. I'll be back next Wednesday with what changed.
— Tarik