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The European Commission has proposed targeted amendments to the EU Deforestation Regulation (EUDR) to streamline implementation for downstream operators and traders, and for micro- and small undertakings, while preserving full due diligence obligations at the point where products are first placed on the EU market.
The EUDR aims to tackle deforestation and forest degradation by regulating the placement and export of certain products within the EU market. It imposes supply chain due diligence obligations on operators and traders of relevant commodities (cattle, cocoa, coffee, oil palm, rubber, soya and wood) and specified derived products.
Key Proposed Changes:
- Downstream operators and traders—such as retailers and large manufacturers who sell EUDR-relevant products after they enter the EU market would not be required to submit due diligence statements. One submission from the upstream operator at the initial EU entry point would cover the entire supply chain.
- Micro and small primary operators in low-risk countries – would be subject to a simplified due diligence regime.
- Timing – for large and medium entities, the EUDR's substantive obligations would still apply from 30 December 2025, but with a six-month enforcement grace period for checks and enforcement measures until 30 June 2026. Application for micro and small enterprises would commence from 30 December 2026.
Next Steps
The Commission has called on the European Parliament and the
Council to adopt the proposal by the end of this year. It is also
preparing contingency plans, as if the amendments are not adopted
in time, the EUDR will enter into application, without the proposed
simplifications, on 30 December 2025.
What this Means
Large and medium sized entities should continue preparing for
application in December 2025, noting the potential six-month
enforcement grace period if the proposal is adopted.
This article contains a general summary of developments and is not a complete or definitive statement of the law. Specific legal advice should be obtained where appropriate.
