EUDR: European Commission plans delay and simplification

The European Commission has proposed amendments to the EU Deforestation Regulation (EUDR), formally Regulation (EU) 2023/1115, which aims to ensure that products placed on or exported from the EU market are deforestation-free and legally produced.

Published on 21 October 2025, the proposal limits the one-year delay to micro and small companies, extending their compliance deadline to 30 December 2026. Medium and large operators remain subject to the 30 December 2025 application date, but would benefit from a six-month grace period for enforcement.

The proposal introduces targeted changes to support the proper functioning of the EUDR IT system (TRACES NT) and to reduce unnecessary duplication for downstream actors in supply chains.

Key changes proposed by the European Commission

1. One-year postponement for micro and small companies
   • Micro and small enterprises would have until 30 December 2026 to comply, one year later than the original date.
   • Medium and large operators remain bound by the 30 December 2025 application date, but enforcement authorities would apply a six-month grace period.
   • Read more on the size classifications under the EUDR here
2. “First-touch” due diligence principle
   
   • Only the first operator or importer placing a listed product on the EU market must carry out full due diligence and submit a Due Diligence Statement (DDS) in TRACES NT.
   • Downstream operators and traders will no longer submit their own DDS; instead, they must reference the upstream DDS and maintain traceability through reference numbers.

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3. Registration and traceability still required
   • Non-SME downstream operators and traders must still register in the IT system, given their influence on supply-chain compliance.
   • All actors remain responsible for ensuring traceability and for passing on declaration identifiers.
4. Transition period of 6 months
   • Medium and large companies get a grace-period (“transition period”) of six months for enforcement of the obligations starting 30. December 2025.

Who is affected and when

Background of the proposal

On 23 September 2025, EU Commissioner Jessika Roswall informed the European Parliament and the Council that TRACES NT, the IT system for EUDR filings, might not yet support the expected data volume.

This triggered the formal Commission proposal of 21 October 2025, which combines technical readiness adjustments with simplifications for SMEs and downstream operators.

Next steps for it to become law

The proposal must follow the ordinary legislative procedure:

• The European Parliament and the Council of the EU will review and potentially amend the text before voting on adoption.
• Until publication in the EU Official Journal, the current EUDR deadlines remain legally binding.

Expected timeline for the changes

Parliamentary discussions are expected to begin in November 2025. If approved quickly, the amendment could enter into force in late 2025 or early 2026. A longer review could shift adoption to mid-2026, though the direction toward simplification and SME relief is unlikely to change.

Practical recommendations for companies

• Continue preparing for EUDR compliance: map supplier origins, gather geolocation data, and document legality checks.
• Establish internal systems to link shipments and SKUs to DDS references once available.
• Use the expected simplifications to streamline data collection across supply chains, not to postpone preparations.

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