EU Commission Proposes Targeted Simplifications to Support EUDR Implementation

The European Commission has proposed a series of “targeted” amendments to the EU Deforestation Regulation (EUDR) aimed at easing administrative burdens and ensuring that the necessary EU-wide IT infrastructure is operational in time for the regulation’s entry into application.

The EUDR, adopted in 2023, requires that key commodities and products placed on the EU market — including cattle, cocoa, coffee, palm oil, rubber, soy, and timber — are not linked to deforestation or forest degradation. The law is set to apply from 30 December 2025 for large and medium-sized companies, while micro and small operators face a deferred start date.

Following speculation about a potential one-year postponement, the Commission confirmed that the December 2025 start date remains unchanged, opting instead for targeted simplifications to help authorities and companies prepare for implementation.

Key proposed amendments

1. New category for “downstream operators”
A new classification will cover operators that commercialize relevant products but do not place them on the EU market for the first time.
These downstream operators — similar to traders — will no longer need to submit their own due diligence statements (DDS). Instead, they must retain and forward the reference number from the upstream operator’s DDS. Responsibility for compliance will rest with the primary importer or producer placing the product on the EU market.

2. Simplified obligations for “micro and small primary operators”
Operators in low-risk countries who only produce and export their own goods will be able to submit a single simplified declaration via the EUDR IT system. Where equivalent data exists in a national EU database, that may also suffice.
These provisions will apply from 30 December 2026, one year after the main regulation enters into force.

3. Deferred enforcement for larger companies
While the EUDR formally applies from 30 December 2025, enforcement under Articles 16–19, 22 and 24 will be delayed until 30 June 2026. During this transitional period, competent authorities will focus on issuing warnings and recommendations rather than imposing penalties.
However, customs checks under Article 26 will still begin as planned in December 2025.

4. Long-term review in 2030
A general review of the EUDR is now scheduled for 30 June 2030, when the Commission will assess the overall impact and effectiveness of these amendments.

Context: Simplification under the EU’s competitiveness agenda

The new proposal explicitly references Mario Draghi’s 2024 report on European competitiveness, which identified administrative complexity as one of the main barriers to business growth in the EU.
The Commission’s initiative forms part of a broader effort to make sustainability regulation more proportionate, digital, and predictable without compromising environmental ambition.

Next steps

The proposed amendments are not yet law. They must still be adopted by both the European Parliament and the Council before they can take effect.

The Commission has said it expects an agreement by year-end 2025, but is preparing contingency plans in case of procedural delays.
Given the tight timeline before the regulation’s application date, affected companies face continued uncertainty and should monitor developments closely.

For companies in scope, early preparation — including data collection, supplier traceability, and IT readiness — remains essential to avoid last-minute compliance risks.

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