The European Commission proposes new amendments to the EUDR

The European Commission has proposed further amendments to the EU Regulation on Deforestation-Free Products – Regulation (EU) 2023/1115 (the EUDR) – after weeks of speculation that the existing IT system could not cope with the demands of the original regime.

What you need to know

• Simplified due diligence processes will now apply to "downstream" operators and traders, including an even more simplified procedure for newly-defined "micro and small primary operators".

• A six-month grace period will be granted to large and medium-sized companies, with enforcement measures and checks deferred until 30 June 2026.

• The EUDR will apply to micro and small operators from 30 December 2026.

After several weeks of uncertainty and speculation, the European Commission released its proposal to revise the EUDR on 21 October 2025. The proposal follows an announcement by the EU Commissioner for the Environment regarding a possible one-year postponement to the EUDR's implementation, reportedly due to IT issues, after the regulation had already been delayed just one year ago. 

With these new targeted amendments, the European Commission aims to streamline and reduce the EUDR's reporting requirements, while maintaining its fundamental objective of preventing deforestation. However, the proposal goes beyond the postponement initially announced by the EU Commissioner, and not only intervenes to ensure the proper functioning of the IT system, but also introduces some changes to simplify the EUDR with the intention of alleviating the administrative burden on supply chain actors.

Key proposed changes

• Simplified reporting requirements for the newly defined category of downstream operators, as well as traders, who are no longer required to produce and submit due diligence statements. However, non-SME downstream operators and traders must still register in the IT system, and all of them (including small and medium-sized ones) are required to collect and keep certain information to ensure full traceability. 
• Introduction of a new category of micro and small primary operators in low-risk countries, who 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, before placing the relevant product on the market. 
• Adjusted timeline & phased implementation: 
  • The deadline for micro and small operators to comply with the EUDR is extended to 30 December 2026, from 30 June 2026.
  • Large and medium operators and traders will need to comply with the EUDR from 30 December 2025, as already scheduled. However, these actors will benefit from a six-month grace period to facilitate a gradual phase-in. This means that the competent authorities will not be required to carry out checks and other enforcement measures until 30 June 2026. 
• The date for the general review of the EUDR, which may include a potential extension of the scope of the regulation, has been changed to 30 June 2030.

Next Steps 

The proposal follows the ordinary legislative procedure, which requires the European Parliament, the Council of the EU and the European Commission to reach a shared position, which will then need to be formally adopted by both the European Parliament and the Council before it can come into effect. 

The European Commission has expressed its intention to secure a deal before the end of the year. However it has also announced preparations for "contingency plans" to ensure that, in the event the proposal is not adopted in time, the current EUDR framework will be applicable from the designated date (30 December 2025). At this stage, there is no additional information regarding these plans.

It is worth noting that last year's proposal to amend the entry into force of the EUDR progressed smoothly in the Council of the EU. However, in the European Parliament attempts by some lawmakers to reopen discussions on the substance of the regulation – notably by introducing a "zero-risk category" – generated significant debate. A recurrence of such developments cannot be ruled out.

 The drive for simplification remains a central theme on the EU agenda, and calls to revisit the EUDR have been strong, both at the Member State level and, in particular, within the European Parliament. Additionally, international pressure from countries such as Brazil, Indonesia, and especially the US, could influence the discussions surrounding the EUDR.

Other authors: Julie Vaughan, Counsel, Aled McNeile, Junior Associate and Freddie Freeman, Trainee

Want to know more? 

• The EU Regulation on Deforestation-Free Products (EUDR) remains in limbo: update and prospects, 15 November 2024
• The EU institutions agreed on postponing the application of the EUDR, the Regulation on Deforestation-Free Products, 18 December 2024
• Simplification of the Regulation on Deforestation-Free Products under the spotlight, 29 April 2025