EU Council and Parliament adopt their negotiating positions on the revision of the Deforestation Regulation

On 19 November and 26 November 2025, the EU Council and the European Parliament, respectively, adopted their negotiating positions on the Commission’s proposal for a targeted revision of the Deforestation Regulation (“EUDR”) (see the Parliament’s press release here and the Council’s  press release here).

The Council’s negotiating mandate and Parliament’s amendments , which are aligned on many key aspects, build on the simplification measures originally proposed by the Commission and includes a one-year postponement of the entry into application of the Regulation to allow operators, traders and authorities to prepare adequately. 

Key takeaways 

Under the Council’s and Parliament’s positions:

• The EUDR would apply from 30 December 2026 for medium and large operators, and from 30 June 2027 for micro and small operators.
• Only operators first placing products on the market would be required to submit due diligence statements .
• Only the first downstream operators would have to keep and pass on the reference number of the initial statement.  
• Micro and small primary operators only would submit a one-off simplified declaration, with no obligation to update it.
• The definition of micro and small primary operators would be broadened, looking only at the relevant parts of balance sheet total, net turnover and average number of employees concerning EUDR activities. 

Background 

On 21 October 2025, the European Commission published a proposal for targeted changes to the EUDR, including a six-month grace period in enforcement for medium and large operators and a six-month postponement for micro and small operators, as well as other simplification measures (see our previous blog post). The Commission called on the European Parliament and the Council to adopt the proposal swiftly before the entry into application of the EUDR by the end of year 2025. 

On 13 November, the European Parliament voted to use the urgency procedure on this file (see EP press release). This allowed the Parliament to move more quickly than has been seen in other files.  

One-year postponement without a grace period

In response to concerns regarding operational readiness and the technical complexities of the new information system, the Council and Parliament agree on removing the Commission’s grace period for large and medium companies. Instead, they favour a uniform one-year postponement of the application of the Regulation for all operators, until 30 December 2026 for medium and large operators and 30 June 2027 for micro and small operators.

Further simplification measures 

The Council and Parliament supported the Commission’s proposed simplification measures, including limiting the requirement to submit due diligence statements only to operators first placing products on the market. Downstream operators and traders would be relieved from submitting separate due diligence statements.

The Council and Parliament also agreed on several additional simplification measures, including:

• Limiting the obligation to collect and transfer reference numbers of due diligence statements and declaration identifiers to only the first downstream operator or trader. This removes the requirement for further downstream operators and traders to handle these numbers within the supply chain.
• Micro and small primary operators would not be required to update the information contained in their simplified one-off declaration following any major changes to the information provided.
• Micro and small primary operators could choose to replace the geolocation information with the postal address of all plots of land or the postal address of the establishment from which the relevant commodities have been produced, provided that the postal address clearly corresponds to the geographic location of the plots or establishment concerned.
• Broadening 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 relating to their EUDR activities do not exceed the limits for at least two of these three criteria for micro and small undertakings as set out in the Accounting Directive 2013/34/EU, would be treated as micro and small primary operators (instead of considering all activities).

The Council and Parliament further agree on tasking the European Commission to carry out a simplification review by 30 April 2026, evaluating the administrative burden and impact of the Regulation, particularly for micro and small operators. The Commission would outline in its report possible ways to address any issues identified, including through technical guidelines, improvements to the IT system, delegated or implementing acts and, where appropriate, a legislative proposal.

The Parliament’s amendments (which do not feature in the Council’s mandate) also include the following: 

• The establishment of a permanent stakeholder group to ensure continued exchanges with experts, stakeholders and operators to develop best practices and collect technical feedback;
• Remove products falling under Chapter 49 of the Combined Nomenclature (including printed books, newspapers, pictures and other products of the printing industry, manuscripts, typescripts and plans, of paper), from Annex I of the Regulation, thereby excluding them from the Regulation’s scope;
• Require national competent authorities, before the Regulation enters into application, to take into account relevant information and give due consideration to communications from the Commission concerning IT problems and errors in the Information System, before imposing administrative sanctions on operators once the Regulation applies.

Next steps 

The Parliament and Council are now ready to start negotiations in order to reach a final agreement in the coming weeks and before the current EUDR becomes applicable on 30 December 2025.

Further reading 

For more information on the EUDR, see our previous blog posts:

• Deforestation Regulation: EU imposes new due diligence duties on operators and traders

• EU Deforestation Regulation: final green light for the one-year postponement 

• EU Deforestation Regulation: country risk classification adopted by the Commission

• EU: Commission publishes new guidance and draft Delegated Act to simplify due diligence requirements under Deforestation Regulation

• EU: Commission publishes proposal with targeted changes to Deforestation Regulation