EU Deforestation Regulation Amendments: Deferred Timelines and Simplification Measures
The EU Deforestation Regulation ("EUDR") aims to reduce deforestation and forest degradation, and their corresponding impacts on climate change, by ensuring that in-scope commodities and products placed on the EU market (or exported) are deforestation-free, produced in accordance with the laws of the country of production, and covered by a due-diligence statement.
On October 21, 2025, the Commission published a new proposal ("Proposal") to amend the EUDR. The Proposal includes a targeted deferral for micro- and small‑sized operators to December 30, 2026, coupled with a package of simplifications intended to reduce administrative burden and ensure the operability of the EU information system.
The Proposal formally introduces a new category of "downstream operators," defined as any natural or legal person who, in the course of a commercial activity, places on the market or exports relevant products that are made using relevant products (i.e., further down the supply chain) and are already covered by a due-diligence statement or a simplified declaration. The proposal also updates the definition of "trader" to distinguish it from "operator" and "downstream operator." Downstream operators and traders are no longer subject to the obligation to file due-diligence statements. They must, however, maintain traceability by collecting and retaining information on the operators, downstream operators, or the traders who have supplied the relevant products to them, as well as passing on due-diligence statement reference numbers or declaration identifiers. Downstream operators and traders that are non-small- and medium-sized enterprises must also register in the EUDR information system prior to placing or making available relevant products on the market or exporting them. The Commission's stated aim is to reduce the volume and avoid system overload caused by highly transactional, automated submissions.
For primary production at small scale in countries classified as low risk, the Proposal creates a "micro and small primary operator" subcategory. These operators would be exempt from submitting due-diligence statements and should instead file a one‑time simplified declaration to obtain a declaration identifier, which must then accompany their products throughout the chain. Where equivalent traceability data already exist in European Union or national databases, Member States may transmit the information to the EUDR system, allowing the operator to rely on the assigned identifier without a separate declaration. The Proposal also clarifies that for these operators, the geolocation requirement may be fulfilled by providing a postal address of all plots.
While under the Proposal, the EUDR would still apply beginning December 30, 2025, for all operators other than micro- and small-sized undertakings, the Proposal introduced a targeted deferral for micro- and small-sized operators to December 30, 2026. However, the Council and the Parliament reached a provisional political agreement on December 4, 2025, supporting the simplification measures set out in the Proposal, while additionally providing a general one-year postponement of the EUDR's entry into application. Under the agreement, the general application date would shift to December 30, 2026, and the application date for micro- and small-sized operators to June 30, 2027. It was also agreed that by April 30, 2026, the Commission must present a report to assess the law's impact and administrative burden, in particular for micro- and small-sized operators. Finally, the co-legislators agreed to exclude printed products from the scope of the regulation, as requested by the Parliament.
The Parliament must now vote on the deal during its December 15-18, 2025, plenary session. The Council's formal approval is expected to take place shortly. Given the shared support for simplification and the alignment between the Council and Parliament on a general one-year postponement, it is reasonable to expect that the EUDR will be amended before the current version takes effect on December 30, 2025.
