EUDR update: Commission proposes limited amendments and only a partial delay to implementation

Yesterday, 21 October 2025, the European Commission presented a legislative proposal to amend the EU Deforestation Regulation (EU 2023/1115). This proposal follows earlier indications from Commissioner Jessika Roswall, who had stated that she would seek a one-year delay to allow more time for system readiness and compliance.

According to the Commission, among other things, the amendments aim to address concerns about the capacity of the EU Information System to handle the expected volume of due diligence statements. These technical constraints apparently would have risked slowing the system to unacceptable levels or causing repeated disruptions, potentially hindering companies from complying with the Regulation.

A targeted delay of the application date and grace period for enforcement

The proposal seeks to postpone the EUDR application date, but only for small and micro enterprises, moving by six months the date from 30 June 2026 to 30 December 2026. For larger operators and traders, the original application date of 30 December 2025 remains unchanged.

A six-month grace period would be implemented for certain enforcement obligations by Competent Authorities. However, this does not exempt the large and medium operators from their obligations, which start from 30 December 2025.

This is the second time that a delay has been proposed. However, the Commission has emphasised that until the legislative process concludes and the proposal is adopted by both the Council and the European Parliament, the current application dates remain legally in force.

The proposal also adjusts the relationship between the EUDR and the EU Timber Regulation (EUTR). Under the new timeline the EUTR would continue to apply:

• until 30 December 2026 for timber and timber products included within the Annex of that regulation and placed on market by all micro and small primary operators¹.
• for timber and timber products produced before 29 June 2023 but placed on the market on or between 30 December 2026 until 31 December 2028 by micro and small operators².
• for timber and timber products produced before 29 June 2023 but placed on the market on or between 30 December 2025 until 31 December 2028 by all other types of operators.

Reduced obligations for certain types of operator and trader

Beyond the timeline adjustments, the proposal introduces significant changes to who submits due diligence statements. The Commission proposal removes the obligation for downstream operators and traders to submit statements to the EU Information System or to verify the quality of due diligence systems implemented by upstream operators.

The implication of this is that, effectively, only one due diligence statement would now be required per supply chain into the EU, to be submitted by the operator who first places the product on the EU market. Exports of relevant products from the EU still also require a due diligence statement.

Furthermore, the Commission proposal removes all obligations on downstream non-SME operators and non-SME traders to ‘ascertain’ that the due diligence by upstream entities is in line with EUDR requirements. This is with one exception³  in which - in the case of substantiated concerns - they would be obliged to verify that due diligence had been properly exercised and that no or only a negligible risk was found.

Finally, and new category of operator is defined in the proposal: micro and small primary operators. These are operators who are natural persons or a micro- or small-sized undertakings, established in a country classified as low risk according to the Country Benchmarks, which place on the market or exports products that the operator itself has grown, harvested or raised (as regards cattle). For these entities, they would instead be required to submit a ‘simplified declaration’, further reducing administrative complexity.

The Commission argues that all the above measures would prevent duplication, reduce technical strain on the EU Information System and ease compliance for smaller actors, without undermining the core aims of the Regulation.

Implications for businesses

If adopted, these changes would alter how downstream operators and traders, and micro and small primary operators, prepare for EUDR alignment. Companies that import relevant products into the EU or export them would continue their preparations as planned, while smaller importers would have a slightly longer transition period to implement systems and ensure data accuracy.

The simplification of due diligence submissions is expected to reduce reporting obligations for many businesses, particularly those involved in downstream trading. However, the regulation’s fundamental requirements remain unchanged. Products placed or made available on the EU market must still be deforestation-free and legally produced.

Until the legislative process is finalised, businesses should not assume the amendments will take effect as proposed. If the proposal is not adopted before the end of 2025, the EUDR will proceed under its current timeline, requiring most operators to comply by 30 December 2025 and 30 June 2026 for micro and small enterprises.

Next steps

The proposal will now be examined by the Council and then the European Parliament, with each developing their own mandates. Given the urgency, the Commission has called for an accelerated review and adoption process so that the proposal can be adopted before the end of 2025.

Preferred by Nature will continue to follow the legislative process and report on further developments as they unfold. Future updates related to the EUDR’s implementation and amendments will be covered in new articles as official information becomes available.

To support companies in preparing for the EUDR, Preferred by Nature will hold workshops this November in the Netherlands, Germany, Ireland and France. Each session offers practical guidance on establishing deforestation-free and legal supply chains. Learn more: https://www.preferredbynature.org/events-training

<sub>1. Operators who are natural persons or a micro- or small-sized undertakings, established in a country classified as low risk according to the Country Benchmarks, which places on the market or exports relevant products that the operator itself has grown, harvested, or raised, as regards cattle.
2. Operators that by 31 December 2024 were established as micro-undertakings or small undertakings.
3. See new proposed Article 5(7)</sub>