European Union Deforestation Regulation (EUDR): What's happened?

Following months of proposed changes to the EU Deforestation Regulation (EUDR), on 4 December 2025 EU institutions reached a provisional agreement that will see several simplifications to the EUDR regulation as well as delayed application dates.

In this blog post, we summarise what happened and how it may impact how your business implements EUDR.

What’s happened over the last two months?

On 21 October 2025, the European Commission published the first proposal for amendments to the EUDR. The European Council followed with further simplifications on 19 November 2025, and then finally the European Parliament adopted its own position and published their proposal for the EUDR on 26 November 2025.

The Commission justified the amendments using the following reasons:

1) The administrative burden placed on European companies, particularly for SMEs, is considered to be misaligned with European competitiveness.

2) The projected number of Due Diligence Statements generated by the EUDR Information System will exceed the current capacity of the platform.

With all three institutions having set out their positions, the Commission, Council, and Parliament entered trilogue negotiations on Thursday 4 December 2025 to agree on a final compromise text. Although talks were expected to run until a vote in the week of 15 December 2025, the Council and Parliament reached a deal on the targeted revision on the evening of 4 December 2025.

Has anything changed yet?

No, not yet but changes are on the horizon. The Council and the Parliament have reached a provisional political agreement on the amendments to the regulation, ultimately aligning to simplify the existing rules and to delay the application date. The regulation still needs to be formally adopted by both the Council and Parliament and published in the Official Journal of the EU before the current application date (30 December 2025). Only then will the new dates and obligations become legally binding.

What’s a quick summary of the proposed changes?

Delayed application dates

To give SMEs more time to adapt to the new requirements, the Commission proposed to postpone the date of application for small and micro companies from 30 June 2026 to 30 December 2026. The Commission and the Parliament then expanded the delay to all economic operators, meaning that the new general application would be 30 December 2026 for Medium and Large businesses and the 30 June 2027 for Micro and Small businesses.

Simplification for new operators

Specific areas of the regulation were identified for simplification to both reduce the administrative burden for companies, while also reducing the number of Due Diligence Statements being generated through the EUDR Information System (Traces NT). The Commission outlined two new economic operator categories: “Downstream operator” and “Micro and small primary operator”. Both new economic operator types are being introduced to clearly distinguish the simplifications to their due diligence obligations, which ultimately eliminates the requirement to conduct due diligence and submit statements, reducing the load on the EUDR Information System.

Exemption for printed products

Both the Council and Parliament agreed to remove certain printed products, such as books, newspapers, and printed images, from the list of Annex II, to provide further alleviation of the administrative burden.

Simplification review in April 2026

To ensure that the amendments have the desired outcome of reducing administrative burden and EUDR Information System throughput, the Council and Parliament have recommended that a new “simplification review” is conducted by 30 April 2026. The Commission is tasked with conducting this review, producing a report that outlines additional mechanisms to address any issues, which could include further simplifications in a new legislative proposal.

For a more detailed outline of the proposed amendments from the Commission, Council and Parliament, that provides a clearer overview on how the regulation could impact your company, please see the Appendix.

How did we get here?

Since the European Green Deal in 2020, a suite of landmark laws has been published to tackle climate change and biodiversity loss in supply chains, including the EUDR, Corporate Sustainability Due Diligence Directive (CSDDD), EU Green Claims Directive, and many others. A parallel trend has seen many of these laws dismantled before they even enter into application. The timing of the EU Deforestation Regulation puts it on the backfoot and exposes it to alternative EU priorities.

• In April 2021, “Better Regulation: Joining forces to make better laws” (European Commission, 2021) pushed through an agenda to support EU competitiveness by ensuring the EU laws deliver on their objectives without imposing unnecessary burden.
• In March 2023, the Commission identified the need to rationalise and simplify reporting requirements. The report “Long-term competitiveness of the EU: Looking beyond 2030” committed to a 25% reduction of all administrative costs and 35% for small and medium-sized enterprises (SMEs).
• In February 2024, “The Future of European Competitiveness: A competitiveness strategy for Europe”, written by Marco Dragh, prescribed to Europe a new roadmap for economic growth that is based on streamlining regulatory requirements and reducing administrative burden, particularly for SME’s companies that are prioritised as Europe tries to close its innovation gap with the rest of the world.

Recent regulations out of Europe have prioritised economic growth over environmental protection. We have seen the impact of simplification of sustainability regulation manifesting as the “Omnibus I package” , which has resulted in fewer companies reporting less information, which overall reduces the level of traceability through supply chains. Many had anticipated that the EUDR was next in the firing line. The European Commission stated that amendments were pushed through via stakeholders. Regulatory trends have provided ammunition for industry lobbyists and political parties to push deregulation agendas and weaken the EU’s capacity to address deforestation.

What does this mean for businesses?

The amendments should not be seen as an invitation to slow preparations for the incoming regulation, but to catch up on lost time. Businesses should continue to get ready for compliance by implementing due diligence systems and engaging suppliers to gather documentation. Requirements will only change for some businesses, and all EU supply chains have an Operator with EUDR responsibilities. All EUDR products must still be deforestation-free and legally produced in the country of harvest, so the overall goal for 100% traceability and robust due diligence remains unchanged.

Companies should monitor the European Union website for the publication of the adopted changes over the next few weeks to ensure they are clear on any amendments to their obligations.

Follow the amendments here.

Soil Association Certification maintains the position that companies need to be prepared for the EUDR. We continue to provide training and due diligence verification services for companies, with up-to-date information and resources. Details can be found on our EUDR webpage.

What does this mean for deforestation and the future of environmental regulation?

We do not know yet what impact of these amendments will have on environmental stability. However, what we do know that the previous year-delay has already projected to have caused 2,300 km2 of forest loss globally, particularly in high-risk countries.

Repeated delays and amendments establish a narrative that market competitiveness is being prioritised over environmental protection, as industry steers the direction of this regulation and undermines regulatory credibility. The Soil Association has signed a joint statement within ClientEarth and 120+ companies, investors and NGOs to call on the European Commission to end “legal uncertainty and implement the EU Deforestation Regulation”.

For more information on how Soil Association Certification can support your business, please visit our EUDR webpage.

Or alternatively, reach out to responsible.sourcing@soilassociation.org.

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EUDR Update December 2025 Appendix 

Timeline of Amendments and Key Proposals

Date	Institution	Details Relevant to Query
21 October 2025	European Commission	Proposed targeted changes to simplify obligations and reduce the load on the Information System.
19 November 2025	Council of the European Union	Agreed upon negotiating position, largely supporting the Commission's simplifications but proposing further postponements and new review requirements.
26 November 2025	European Parliament	Adopted proposals for negotiation, generally aligning with the Council's intent for simplification and delay.

 

Downstream Operator

 All three institutions supported legislative changes to reduce the administrative burden, particularly for downstream actors and SME operators.
The Commission introduced the new definition of "downstream operator" -defined as “any person who places on the market or exports relevant products made using relevant products, all of which are already covered by a due diligence statement or simplified declaration.”

Institution	Key Amendment regarding Downstream Operators
European Commission	Eliminated the requirement for both non-SME downstream operators and non-SME traders to carry out due diligence and submit a due diligence statement. They are still required to register in the information system.
Council of the European Union	Further specified the traceability obligations of downstream operators. The requirement to collect and keep reference numbers of due diligence statements or declaration identifiers should only apply to the first downstream operator and not to subsequent downstream operators further along the supply chain.
European Parliament	Endorsed the Council’s position, confirming that the obligation to collect reference numbers should only apply to the first downstream operator.

 

Micro and Small Primary Operators

 

The Commission introduced the category of "micro and small primary operator" - Defined as “natural persons or micro/small undertakings established in a low-risk country producing their own relevant commodities” to simplify their obligations.

Institution	Key Amendment regarding Micro/Small Primary Operators
Commission	Exempted these operators from submitting a full due diligence statement, requiring instead a one-time simplified declaration in the information system to receive a declaration identifier. Proposed that the geolocation requirement could be replaced by the postal address of the plots.
Council	Expanded the definition of "micro and small primary operator" to include operators who might exceed SME criteria overall, but whose turnover, balance sheet total, and employee count related specifically to their EUDR activities remain within the SME limits. Also confirmed they could use the postal address of the plots/establishment instead of geolocation data.
Parliament	Fully endorsed the expanded definition and the provision allowing the use of the postal address (provided it clearly corresponds to the geographic location).

 

Delay & Review Timelines:

Application Delay
The proposal to implement a significant delay in the application dates came primarily through the process following the Commission’s initial proposal, though the need for simplification and postponement was voiced by stakeholders and trade partners.

European Commission Proposed a general application date for core obligations starting 30 December 2025. It set the deferred date for SMEs (micro/small operators) on 30 December 2026.

The Council of the European Union proposed postponing the application of the core obligations by 12 months. This shifted the general application date to 30 December 2026. It also shifted the deferred date for SMEs to 30 June 2027.

European Parliament also explicitly proposed postponing the application date of the obligations by 12 months, supporting the 30 December 2026 date for general application and the 30 June 2027 date for SMEs.

Simplification Review

The original EUDR text already included a schedule for evaluation and review, with a general review set for 30 June 2028. The subsequent legislative efforts involved changing this existing schedule and adding new review mechanisms.

Commission aligning the review process by merging the previously mandated impact assessments (scheduled for 2024 and 2025) into the general review. It proposed changing the date for the general review from 30 June 2028 to 30 June 2030 to account for the postponed entry into application.

Council proposed a new review mechanism: a simplification review to be carried out by the Commission by 30 April 2026, evaluating the administrative burden and impact, particularly for micro and small operators and the functionality of the Information System. The Council retained the proposed 30 June 2030 date for the general review.

Parliament also proposed the new simplification review by 30 April 2026, intending to evaluate the administrative burden and impact, especially for micro and small operators. The Parliament also retained the proposed 30 June 2030 date for the general review.