EU Deforestation Regulation Reset: Simplified Compliance and Extended Implementation

At a Glance

• On 4 December 2025, the Council of the EU and the European Parliament reached a provisional agreement to revise the EU Deforestation Regulation (Regulation (EU) 2023/1115, EUDR) (the Provisional Agreement).
• The Provisional Agreement narrowed the scope of application, simplified compliance for many operators, and extended key implementation deadlines.

EUDR Recap

The EU Deforestation Regulation (EUDR) was adopted in 2023 to restrict the sale or exportation of certain commodities unless they are:

1. Deforestation-free.
2. Produced in compliance with the relevant laws of the country of origin.
3. Covered by a due diligence statement (DDS) confirming that the business has checked the origin of the products and that they meet EUDR requirements.

EUDR commodities cover key agricultural goods — cattle, cocoa, coffee, palm oil, rubber, soy, and timber — plus some of their derivatives (such as leather, chocolate, or paper).

All operators in a supply chain involving EUDR commodities (including traders, distributors, and downstream handlers), were expected to submit their own DDS.

The Amended Regulation: Key Changes

Streamlined Due Diligence Obligations

Under the Amended Regulation, DDS requirements now apply only to first-in-line operators, meaning only operators who first place a product on the EU market. Subsequent operators will no longer be required to file an independent DDS; only the first downstream operators will have to keep and pass on the reference number of the initial DDS. This change significantly reduces repetitive reporting across supply chains, which industry stakeholders have consistently highlighted as an unnecessary compliance burden.

Extended Compliance Timelines

Following widespread calls from industry and Member States for additional time to address technical and operational challenges associated with the EUDR's implementation, the main compliance dates have shifted under the Amended Regulation as follows:

Adjusted Scope

Notably, the core commodities list remains intact under the Amended Regulation, however, several paper derivatives (including printed books, brochures, leaflets, newspapers, journals, periodicals, and similar printed materials) have been removed from the scope of the EUDR due to their lower risk of deforestation. Significantly, paper, printed cartons, wallpaper, stationary, diaries, and labels remain within scope, unless they are fully recycled.

Broadened Definition of Micro and Small Operators

The Amended Regulation expands the definition of micro and small primary operators so that those able to demonstrate that the parts of their balance sheet total, net turnover, and average number of employees which relate to the relevant commodities and the relevant products do not exceed the limits for at least two of the three criteria set out below will be treated as micro and small primary operators:

Micro-undertakings

1. Balance sheet total: EUR350,000
2. Net turnover: EUR 700,000
3. Average number of employees during the financial year: 10

Small undertakings

1. Balance sheet total: EUR4,000,000
2. Net turnover: EUR 8,000,000
3. Average number of employees during the financial year: 50

Simplified Reporting for Micro and Small Operators

To address the disproportionate impact on smaller entities, under the Amended Regulation, micro and small primary operators will only submit a one-off simplified declaration, with no obligation to update it. This measure seeks to maintain traceability while reducing the administrative load for smaller organisations.

Micro and small primary operators will also have the option to replace the required geolocation information with the postal address of the plots of land or establishment concerned, provided that the postal address clearly corresponds to the geographic location of the same. 

Review Clause

The Amended Regulation includes a review clause requiring the European Commission to assess the EUDR's administrative burden and effectiveness, with a report due by 30 April 2026. Importantly, the Commission will be required to outline possible ways to address any issues identified, including through technical guidelines, upgrades to the IT system, delegated or implementing acts, and, where appropriate, a legislative proposal.

Impact on Market Participants

• First-in-line operators (i.e., those introducing in-scope products into the EU market) will become the central compliance anchors for EUDR due diligence, responsible for preparing and submitting the key DDS.
• Downstream operators (i.e., those placing on the market products incorporating inputs already covered by a DDS) will need to adjust internal processes to capture and retain DDS reference numbers rather than conducting their own detailed due diligence exercise or making their own DDS statement. Where operators are relying on an upstream DDS, they should still assess supplier maturity by verifying that the supplier can provide a valid DDS for the relevant EUDR product and spot checking the accuracy and completeness of the information provided.

Next Steps and Outlook

The one-year postponement will provide businesses with valuable time to reinforce internal processes, assess supply chain risks, train suppliers, and refine controls. Downstream operators should use this time to prepare for engagement with the simplified process and to adapt existing supply-chain documentation and IT systems to facilitate the new reference-number system. 

We are following the simplification review and will report further once the findings are published later this spring.