On 21 October 2025, the European Commission released its official Proposal to amend the EU Deforestation Regulation (EUDR). Contrary to what announced weeks ago, the Commission is not proposing a delay of the application date for medium and large operators. However, the text includes some alternative measures in place of a delay.
What are the proposed changes to the Deforestation Regulation (EUDR)?
In particular, the Commission’s Proposal to amend Regulation (EU) 2023/1115 includes the following changes:
- Delay for small enterprises. The EUDR application date for micro and small operators will be postponed by six months, going from 30 June 2026 to 30 December 2026. The application date for large and medium-sized operators remains unchanged (30 December 2025).
- Grace period of six months for enforcement. Large and medium operators will enjoy a six-month grace period where they will not be at risk of enforcement. In this sense, the application date for competent authorities’ obligations to carry out measures related to enforcement of the EUDR is moved to 30 June 2026 for operators, downstream operators, and traders, and to 30 December 2026 for micro and small operators.
- Exemptions for non-SME due diligence. Large downstream operators are exempted from the obligations to ensure that due diligence was exercised and from the obligation to submit their own due diligence statements. This exemption already applies to SME operators and traders. This change is proposed in order to reduce reporting requirements and decrease interactions with the information system.
- One-time simplified declaration. Micro and small primary operators are required to submit a one-time simplified declaration in the information system. Alternatively, they can provide the relevant information via a system or database set up under Union or Member State legislation. The relevant information includes data on geolocation or the postal address of all plots of land where the relevant commodities are produced.
Next steps in the legislative process
The Proposal requires the approval of the European Parliament and the Council of the EU. This can result into the second change to the Regulation initial text.
To understand whether your business must comply with this Regulation, contact us here or at prodlaw@obelis.net.
References:
European Commission (2025). Proposal for a Regulation of the European Parliament and the Council amending Regulation (EU) 2023/1115 as regards certain obligations of operators and traders. Retrieved on 24/10/2025.
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