On 21 October 2025, the European Commission officially published a Proposal to amend the EU Deforestation Regulation (EUDR), as part of its broader simplification efforts. While the core timeline remains unchanged for most businesses, the proposal introduces targeted adjustments that could affect compliance strategies across the supply chain.

Key Highlights from the Proposal

Contrary to earlier expectations on a potential one-year delay, the proposal does not delay the overall application of the EUDR. Instead, it introduces targeted extensions for micro and small primary operators, allowing them to comply by 30 December 2026 (instead of 30 June 2026). For all other operators, the regulation still enters into force on 30 December 2025, with a six-month grace period for enforcement extending to 30 June 2026. Additionally, the proposal attempts to shift the responsibilities to upstream operators, while clarifying the distinction between traders and downstream operators.

What’s Changing?

The proposal introduces several important updates:

  • New Definitions
    • Micro and Small Primary Operators – Now formally recognized, with simplified compliance obligations.  This new subcategory covers natural persons, micro and small undertakings established in low-risk countries that produce and place their own products on the market.
    • Downstream Operators – Defined as entities placing products on the market that are made using relevant products that are already covered by a due diligence statement or by a simplified declaration.
  • Clarified Roles
    • Operators – Entities placing relevant products on the market, excluding downstream operators.
    • Traders – Entities in the supply chain other than operators or downstream operators.
    • Commercial Activity – Now includes processing, distribution, or internal use by not only the operators and traders, but also downstream operators.
    • Authorised Representatives – Entities mandated to act on behalf of operators within the EU.
  • Simplified Due Diligence
    • Micro and small primary operators may submit a one-time simplified declaration instead of repeated statements. This includes the replacement of the geolocation data by the postal address of all the plots where the concerned relevant commodities have been produced.
    • Downstream operators and traders will no longer need to submit a separate DDS (the obligation to ascertain that due diligence was exercised upstream and to submit the DDS is eliminated). Instead, only one submission at the market entry point will suffice for the entire supply chain. Non-SME downstream operators and non-SME traders must still register in the information system and pass on their DDS identifiers to maintain traceability, but they will not be required to submit new statements for each transaction.
  • Digital Infrastructure
    • The Commission is working to stabilize the EUDR’s central information system, which has faced challenges due to high data volumes from large firms.

Implications for Businesses

For companies that do not qualify as micro or small primary operators, the original compliance timeline remains in place. This means:

  • Due diligence obligations begin on 30 December 2025
  • Enforcement grace period ends on 30 June 2026 for non-SME operators and traders and on 30 December 2026 for certain micro and small undertakings

Businesses must ensure they are ready to meet the full scope of EUDR requirements, including robust data collection, supplier documentation, and integration with the EU’s digital reporting system.

Next Steps: Legislative Uncertainty Ahead

While the European Commission has called for a swift adoption of the proposed amendments by the end of 2025, the legislative process remains uncertain and subject to change. The proposal must now be reviewed and approved by both the Council of the European Union and the European Parliament, which may introduce further revisions or delays.

Key considerations include:

  • Timing – Legislative negotiations can be unpredictable. Although the Commission aims for adoption by year-end, procedural complexities or political debates could push timelines further.
  • Content – Amendments may evolve during the review process, potentially altering definitions, obligations, or enforcement mechanisms.
  • Implementation Clarity – Businesses should monitor developments closely, as final guidance and technical details may only emerge after formal adoption.

Our team of experts stands ready to help you navigate these complex developments.