EU: Commission publishes proposal with targeted changes to Deforestation Regulation

On 21 October 2025, the European Commission published a proposal for targeted changes to the EU Deforestation Regulation (“EUDR”) – see:

• Commission press release
• Commission proposal
• Annexes to Commission proposal 

The proposal – key changes

After weeks of speculation and back and forth on a potential (additional) one-year delay to the application of the EUDR, the Commission is now proposing the following changes to the EUDR to reduce regulatory obligations on smaller operators and on the downstream part of the value chain (non-SME downstream operators and traders), and to help prevent overloading the EUDR IT system:

• The EUDR will still enter into force on 30 December 2025 for large and medium sized in-scope companies, but it will only apply to micro and small operators from 30 December 2026 (instead of 30 June 2026).
• There will be a six-month grace period in enforcement for large and medium sized in-scope companies. This means that the competent supervisory authorities will not be required to carry out checks and other measures relating to enforcement until 30 June 2026 for large and medium sized companies (and 30 December 2026 for micro and small operators). Where a competent authority becomes or is made aware of non-compliance with the EUDR before the checks and enforcement powers (in Articles 16-19, Article 22 and Article 24) have come it into force, it may issue warnings to operators and downstream operators and traders, accompanied by recommendations on how to achieve compliance.
• Downstream operators and traders will not be required to submit due diligence statements. Only one submission in the EUDR IT system will be required at the entry point into the EU market for the whole supply chain (i.e., by the operator first placing the relevant products on the market). Non-SME downstream operators and traders will still be required to register in the IT system (since they have a significant influence on supply chains). All downstream operators and traders, whether or not they are SMEs, will still need to collect and keep certain information on the operators, downstream operators, or the traders who have supplied the relevant products to them, and pass on reference numbers and declaration identifiers.
• Micro and small primary operators will only be required to submit one-time simplified due diligence declarations (rather than due diligence statements) into the IT system. The Annex to the Commission’s proposal contains details of the simplified declaration. 

These changes will require the creation of two new definitions – one for a new category of “downstream operators” and one for “micro and small primary operators” (the latter being a natural person or a micro- or small-sized undertaking established in a country classified as low risk placing relevant products on the EU market or exporting them, which they themselves produce, meaning that they grow, harvest, obtain from or raise the relevant commodities in the relevant products themselves.).

The Explanatory Memorandum that appears at the start of the Commission’s proposal explains in detail the existing difficulties with the EUDR IT system and the reasons for wanting to simplify the regulatory burden for both smaller and downstream entities, in line with the Commission’s wider simplification drive (see our Omnibus Tracker). 

The obligations related to the impact assessments to be carried out by the Commission (Article 34) would also be removed under the Commission's proposal. However, the Commission’s duty to carry out a general review of the Regulation would remain, but would be extended by two years to 30 June 2030 (and at least every five years thereafter), so that the review could take into account the experience of the enforcement of the EUDR. 

Next steps 

It is important to remember that at this stage, the proposal is just that – a proposal. The European Parliament and the Council must now discuss (and agree) the Commission's proposal under the “ordinary legislative procedure”. 

The Commission has called on the European Parliament and the Council to adopt the proposal swiftly by the end of year 2025. Time is of the essence as the EUDR is currently scheduled to start applying from 30 December 2025. However, quick agreement may be challenging given the strong statements already issued by parts of the EU institutions about the potential re-opening (for a second time) of the EUDR, which comes against the backdrop of a much more wide-ranging simplification exercise by the EU. 

The Commission’s press release states that it is also working on “contingency plans” so that in-scope entities can comply with their obligations should the proposal not be adopted in time by the European Parliament and Council but it does not say what those contingency plans are.

It is possible that either the Parliament or the Council might try to introduce other changes to the EUDR during negotiations (for example, to create a new “no risk” category). At this stage, it is unclear whether that is likely seeing as there is significant pressure on all sides to reach a final agreement before the end of 2025. Déjà vu, anyone?

Recap: what is the EUDR?

Under the EUDR, any operator or trader who places commodities such as cattle, wood, cocoa, soy, palm oil, coffee, rubber (and some of their derived products, such as leather, chocolate, tyres, or furniture) on the EU market, or exports from it, must be able to prove that the products do not originate from recently deforested land or have contributed to forest degradation. The Regulation imposes mandatory supply chain due diligence requirements on companies placing the relevant commodities on the market (see our previous blog post). 

The principal requirements of the Regulation were originally meant to apply from 30 December 2024, subject to transitional provisions. However, on 23 December 2024, a new Regulation was adopted delaying the application date of the EUDR by one-year, to 30 December 2025 for large and medium sized companies and 30 June 2026 for small and micro enterprises (see our previous blog post).

In May 2025, the Commission adopted an Implementing Regulation classifying countries under the EUDR into three risk categories: low, standard, or high risk. Four countries have been designated as "high risk": Belarus, Myanmar, North Korea, and Russia. 140 countries have been classified as “low risk”, including all EU Member States, the UK, the U.S., Canada, China, Japan, Australia and South Africa. Around 50 countries, including Indonesia, Malaysia or Brazil, have been classified as “standard risk”. This classification determines whether operators can benefit from simplified due diligence obligations under Article 13 of the EUDR, and the level of annual compliance checks to be conducted by supervisory authorities on imports and exports of EUDR-relevant commodities (see our previous blog post). 

See also the additional guidance and FAQs on the EUDR published by the Commission in April 2025 (see our previous blog post).