Overview
Yesterday, on October 21, 2025, the European Commission proposed targeted amendments to the EU Deforestation Regulation (EUDR).
This proposal comes just weeks after the Commission announced the possibility of a one-year delay on the implementation of the EUDR due to issues related to the readability and operability of the IT system which handles transactions for products covered by the EUDR.
Instead, the Commission considers that the proposed amendments, adopted in the general context of its simplification efforts, are the right tool to reduce the administrative burden and overcome potential issues with the IT system.
Please see below a summary of the proposed amendments:
- Obligations for downstream operators and traders. Downstream operators (which are already addressed in the Commission's FAQs document) commercialize relevant EUDR products once they have been already placed on the market. This new category of operators will have the same due diligence obligations as traders, i.e., they do not need to submit a due diligent statement themselves. However, non-SME downstream operators and traders will still be required to register in the information system. The reporting obligations and the responsibility are then focused on the operators that first place products on the market upstream the supply chain.
- New category of micro and small primary operators. Micro- or small-sized undertakings that are established in a country classified as low risk, whether they place relevant products on the market or export products that they produce, will only be required to submit a one-time simplified declaration in the information system or to provide the relevant information via an alternative system or database.
- New transitional periods and application dates. Obligations to micro and small operators will apply only from December 30, 2026. For other undertakings, the application date of enforcement measures and checks will be deferred to June 30, 2026. Until that date, where a competent authority becomes or is made aware of non-compliance with the EUDR, it may issue warnings to the relevant undertaking accompanied by recommendations to achieve compliance.
- New date and scope of the EUDR review. The date for a general review of the EUDR is changed to June 30, 2030, which will also evaluate the impact of the proposed amendments.
As next steps, the proposed amendments will follow the ordinary legislative procedure, meaning the Parliament and the Council must agree on the final text. The Commission expects a smooth discussion and agreement before the end of the year 2025 but has also expressed its intention to work on contingency plans should the EUDR enter into application on December 30, 2025.
We will continue to monitor any developments and remain at your disposal should you have any questions.
