EU resets the countdown on the EUDR and postpones the Regulation once again

Further amendments to the EU Deforestation Regulation have been made just in time. Following a proposal by the European Commission, the EUDR was comprehensively revised by the Parliament and the Council.

The news continues to emerge regarding the EUDR: The European Deforestation Regulation (EUDR) was originally scheduled to apply to medium-sized and large companies by the end of this year, triggering a wide range of obligations for both operators and traders. The EUDR will only apply twelve months later: for large and medium companies as of 30 December 2026, and for micro and small companies as of 30 June 2027.

The Council and Parliament have reached an agreement and extensively revised the text which has been published in the Official Journal of the European Union on 23 December 2025 and will enter into force three days later.

Changes are far-reaching

In addition to postponing the implementation deadline, a fundamental revision was conducted that significantly simplifies due diligence obligations of several stakeholders.

The obligations for companies in the downstream supply chain was substantially reduced. The Council and Parliament have agreed that the responsibility for submitting a due diligence statement will lie solely with the operators who first place relevant products on the EU market, not with traders or operators who subsequently process or distribute it. Consequently, only these first operators will be required to submit a due diligence statement in the EU information system (TRACES). Downstream operators and traders will be exempt from this obligation and will only have to register in TRACES in case they are considered non-SME downstream operators and traders: the first downstream operator will merely need to collect and retain the reference number of the initial due diligence statement rather than passing it along the entire supply chain.

Furthermore, the obligations for micro and small enterprises importing products into the EU for the first time (operators) were significantly eased. These companies will now only need to submit a one-time simplified declaration in the EU information system according to the new annex III of the EUDR. This adjustment aims to enable companies to meet EUDR requirements more easily without undermining the Regulation’s objectives. For primary producers in countries with low deforestation risk, providing a postal address instead of geolocation coordinates will suffice; additionally, an estimate of production volume is acceptable.

Furthermore, the Council and Parliament agreed to exclude certain printed materials, such as books, newspapers, and printed pictures, from the scope of the EUDR. In Annex I, in the table, the line ‘ex 49 Printed books, newspapers, pictures and other products of the printing industry, manuscripts, typescripts and plans, of paper’ was deleted. Paper and packaging, however, will remain covered.

Background to the recent changes

Following the one-year postponement of the EUDR last year due to political pressure from the Commission, Council and Parliament, the Commission presented a proposal to amend the Regulation on 21 October 2025. This proposal addressed ongoing practical implementation challenges. The focus was particularly on:

• Ensuring the smooth functioning of the EU information system for submitting due diligence statements
• Reducing administrative burdens for micro and small enterprises

The Commission also justified the proposal by citing the need to stabilize the technical infrastructure and improve the practicality of the Regulation. Businesses and Member States repeatedly pointed out that the original requirements, particularly the obligation for all actors in the supply chain to submit their own due diligence statements, were disproportionate for downstream traders and small primary producers. The planned postponement of twelve months is now intended to give all those affected more time to prepare and establish the necessary technical and administrative conditions. Additionally, the Commission announced that it would review further simplifications by April 2026, with the aim of reducing bureaucracy even further.

Looking Ahead

Although the latest developments have drawn criticism and raised concerns that postponing the Regulation's implementation could undermine forest protection by delaying and reducing operators' obligations, Parliament emphasized that the Regulation's core principles remain untouched. In particular, it was highlighted that forests facing a genuine deforestation risk will continue to be protected, while unnecessary obligations will be avoided in areas where such a risk does not exist. The changes will also address the concerns of farmers, forestry companies and businesses, ensuring the framework is practical and implementable.

While some companies welcome the postponement and planned relief measures, others are disappointed and fear that investments already made may be wasted. Nevertheless, the steps already taken to prepare for the EUDR will not have been in vain. Rather than being used to delay implementation, the one-year extension should be seen as an opportunity to strengthen internal processes, analyze supply chain risks, train suppliers and fine-tune control mechanisms. The remaining time can be used by companies to prepare for the new obligations without pressure, and to reorganize internal workflows to ensure smooth EUDR implementation by the end of next year.

CMS can assist with implementing the EUDR within your company and analyzing supply chain risks. Together with our software partner LiveEO, we offer companies a concept combining legal advice and software to implement the EUDR comprehensively.

The authors would like to thank Sonia Drechsler for her contribution to this article.