Review of EU Deforestation Regulation: simplification

Regulation (EU) 2025/2650 of the European Parliament and of the Council of 19 December 2025 amending Regulation (EU) 2023/1115 as regards certain obligations of operators and traders

Update

The European Union (EU) has postponed the application of the EU Deforestation Regulation (EUDR, Regulation 2023/1115) by a further 12 months until 30 December 2026. This is due to concerns about the burden on companies created by the EUDR, as well as technical concerns about the EUDR information system.

The following simplifications to the EUDR are also introduced:

• Only the operators first placing relevant agri-food products (cattle, cocoa, coffee, palm oil, soya) on the EU market must assess the compliance of products with the EUDR, and submit due diligence statements to the EUDR information system.
• “Downstream operators” – companies that subsequently sell or process these products [AR1] [CD2] , but are not the first to place them on the EU market –no longer have to submit their own due diligence statements. The first downstream operator must still be registered in the EUDR information system, and must still ensure full traceability by passing on the reference numbers of all the “deforestation commodities” they use, for use in the due diligence statement. However, this information does not have to be passed further down the supply chain.
• “Micro and small primary operators” who put their own products on the EU market are required to make a one-time simplified declaration of EUDR conformity, rather than a full due diligence statement.

Impacted Products

Cattle, cocoa, coffee, palm oil, soya, and derived products

What is changing?

Downstream operators: no due diligence statements

Under the current EUDR, all operators putting deforestation commodities and derived products on the EU market for the first time must submit a due diligence statement via the EUDR Information System. Currently, for example, both a biscuit manufacturer using chocolate and a large retailer selling the chocolate biscuits would have to submit due diligence statements, even though the supplier of the chocolate had already submitted a due diligence statement in relation to the cocoa used.

Downstream operators do not have to undertake due diligence or submit due diligence statements. The first downstream operator must still be registered in the EUDR information system, and must still ensure full traceability by passing on the due diligence statement reference numbers of all the deforestation commodities they use. However, this information does not have to be passed further down the supply chain.

Small primary operators: simpler requirements

There is also agreement on a new category of micro and small primary operators which covers micro and small businesses (see Background) - irrespective of their legal form – that are established in a country classified as low risk (see EU Deforestation Regulation: Engagement with non-EU countries ) and that put their own products on the EU market.

These operators must only submit a one-time simplified declaration to the information system, instead of a due diligence statement.

12-month postponement

The application of the EUDR is delayed until 30 December 2026. For micro and small operators, the application date is 30 June 2027.

Further simplification?

In addition, under this Regulation, the European Commission must report by 30 April 2026 on the potential administrative burden of the EUDR, indicating how identified issues can be addressed. This could potentially lead to further simplifications of the EUDR.

Why?

The 12-month delay aims to ensure that the EUDR Information System enabling operators to submit due diligence statements will be fully operational; and to allow further time for businesses to prepare for compliance with EUDR requirements.

Timeline

This Regulation applies from 26 December 2025.

The application of EUDR requirements is postponed until 30 December 2026. For micro and small operators, the application date is 30 June 2027.

What are the major implications for exporting countries?

A further delay of 12 months will give non-EU suppliers additional time to prepare for the basic requirements of the EUDR, which are not changed by this proposal. Suppliers must provide importers with geolocation data of the plots of land where commodities are produced, and information demonstrating that commodities were produced in line with relevant national laws. They must also ensure that this data and information can be passed through the supply chain.

Non-EU suppliers will not be affected by changes to the obligations on downstream operators.

The new category of “micro and small primary operators” applies to both EU and non-EU operators. In practice, the impact of the simplified declaration is likely to be limited for non-EU operators, as it only affects operators marketing their own produce.

Background

The EUDR sets out the obligations regarding imports into the EU of products related to cattle, cocoa, coffee, palm oil, rubber, soya, and wood. It requires EU importers to ensure there is no or negligible risk that the production of these commodities contributed to deforestation, or that products were illegally produced according to national law. For a summary of these requirements and implications for suppliers, see The EU Deforestation Regulation: Requirements for Stakeholders outside the European Union.

The EUDR was originally intended to apply from 30 December 2024, but was already postponed once to 30 December 2025.

The definitions of micro and small operators are based on Regulation 2013/34/EU (Art. 3) as follows:

A micro-undertaking is one that does not exceed two of the three following criteria:

• balance sheet total: €450,000
• net turnover: €900,000
• average number of employees during the financial year: 10.

A small undertaking is one that does not exceed two of the three following criteria:

• balance sheet total: €5,000,000
• net turnover: €10,000,000
• average number of employees during the financial year: 50.

“Micro and small primary operators”: operators that place their own products on the market are considered micro and small primary operators even if they exceed the limits of at least two of the three SME-criteria set out above are nevertheless considered if they can demonstrate that their activities in relation to “deforestation commodities” (excluding other commodities they might trade) do not exceed two of the three criteria.

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