While the accompanying impact assessment published with the proposed regulation recognises that smallholders “could face costs to develop or implement systems to allow EU operators to comply with the new requirements” and that “initial short-term impacts caused by EU operators shortening/simplifying supply chains, reducing their number of suppliers and/or switching to lower-risk supply chains may particularly impact smallholders”, this assessment is poorly elaborated on and watered down with the argument that the cut-off date of 2020 could mitigate adverse effects for smallholders.