On October 21, 2025, the European Commission published a draft amendment to Regulation (EU) 2023/1115 of the European Parliament and the Council, commonly referred to as the EUDR Regulation[1]. The proposed changes aim to simplify and clarify the obligations imposed on companies that place on the EU market or export from the EU relevant products which contain, were fed with, or were produced using relevant commodities such as cattle, cocoa, coffee, oil palm, rubber, soy, or wood.

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The draft amendment has been eagerly awaited by businesses and industry organizations following a public statement by EU Environment Commissioner Jessika Roswall, in which she suggested a postponement of the key EUDR obligations. The new proposal responds to concerns raised by market participants regarding technical challenges and the lack of readiness of IT systems. It is designed to enable more efficient implementation of the EUDR while reducing administrative burdens.

The key changes proposed by the European Commission include:

  • Simplified reporting obligations

The Commission has introduced new definitions for two categories of entities to better tailor the regulation to different types of market participants. A “downstream operator” refers to a company that places on the market or exports products made exclusively from raw materials already covered by a due diligence statement or a simplified declaration—this includes, for example, manufacturers of finished goods or processors. Meanwhile, a “micro and small primary operator” is defined as an individual or a micro/small enterprise based in a country classified as low-risk under the EUDR, which places on the market or exports products they have produced themselves.

Companies operating further down the supply chain (the so-called downstream operators and traders) will no longer be required to submit due diligence statements. Instead, they must ensure product traceability by passing on relevant reference and identification numbers from due diligence statements received from their suppliers and register in the TRACES system, unless they qualify as SMEs.

Micro and small primary operators will be exempt from submitting due diligence statements. A one-time simplified declaration in the TRACES system (based on a template annexed to the EUDR) or data submission via a national system will suffice, significantly reducing administrative burden. If the required data is already available in national databases (e.g. for cattle or forest registries), these operators will not need to submit a separate declaration in TRACES.

  • Transition period adjustments – 30 December 2025 remains unchanged

The amendment also extends the implementation period for micro and small enterprises. EUDR obligations will apply to them starting December 30, 2026, instead of the previously set June 30, 2026. For large and medium-sized companies, the effective date remains December 30, 2025, but they will benefit from a six-month grace period for inspections and enforcement. During this period, violations will result in requests for corrective actions rather than penalties.

The draft regulation has been submitted to the European Parliament and the Council of the EU and will follow the standard legislative procedure. This includes committee work, consultations, and amendments, followed by a vote in both institutions. Once adopted, the regulation will be published in the Official Journal of the EU and will enter into force according to the specified timelines.

It is important to note that EU regulations are directly applicable in all Member States, meaning they do not require transposition into national law.

We encourage stakeholders to follow the legislative process closely, as the proposed changes could significantly impact the obligations of companies operating within supply chains of products covered by the EUDR.

[1] Regulation (EU) 2023/1115 of the European Parliament and of the Council of May 31, 2023, on the placing on the Union market and export from the Union of certain goods and products related to deforestation and forest degradation and repealing Regulation (EU) No. 995/2010