The amended EUDR: what has changed and what has remained?

Background

On 21 October 2025, the European Commission published a proposal for targeted amendments to the EUDR. The Commission urged the European Parliament and the Council to adopt the proposal quickly before the EUDR became applicable today, 30 December 2025. On 4 December 2025, the Parliament and the Council reached a political agreement that differed from the Commission's proposals. On 17 and 18 December 2025, the agreement was formally adopted by both bodies and subsequently published in the Official Journal of the European Union on 23 December 2025 as Regulation 2025/2650. 

What has changed?

One-year postponement

The application date of the EUDR is postponed until 30 December 2026 for medium-sized and large operators and traders, and until 30 June 2027 for micro and small operators.

Simplified regime for downstream operators and traders

The amended EUDR introduces a new category: downstream operators. These are operators who place products on the market that have been manufactured by processing products placed on the Union market under a due diligence declaration or simplified declaration. In other words, products that have already been proven to be deforestation-free by means of a due diligence declaration or a simplified declaration. These declarations must include the country of production of the raw materials and the geodata coordinates of the plots from which they originate, as well as a risk assessment. The simplified declaration is an alternative to a full due diligence declaration, introduced under a simplified regime for micro and small primary operators. The simplified declaration is linked  to declaration identifiers that can be referenced. 

Downstream operators are, for example, a chocolate manufacturer using cocoa covered by a due diligence declaration, or a furniture manufacturer using timber covered by a simplified declaration. Downstream operators are not required to submit due diligence declarations; only operators who place products on the Union market for the first time (primary operators) are required to submit due diligence declarations.

The amendments introduce a simplified regime for downstream operators and traders. All downstream operators and traders must collect and retain the following information for five years:

• the name, registered trade name or registered trademark, postal address, email address and, where available, web address of the operators, downstream operators or traders who supplied the relevant products to them;
• reference numbers of the due diligence statements or declaration identifiers associated with those products (only where the supplier is an operator; this is not required if the supplier is another downstream operator or trader);
• the name, registered trade name or registered trademark, postal address, email address and, if available, the web address of the downstream operators or traders to whom they have supplied the relevant product.

Downstream operators and traders that are not SMEs (small and medium-sized enterprises) must register this information in the central European information system for the EUDR managed by the Commission. As a result of the amendments to the EUDR, downstream operators and traders that are not SMEs are no longer required to carry out full due diligence for every product they place on the Union market, sell or export. Under the previous version of the EUDR, this would still have been mandatory.

These downstream operators and traders are also subject to a lighter regime if there is concrete evidence that a product they wish to place on the market, make available or export does not comply with the EUDR. In such cases, downstream operators and traders that are not SMEs must verify that due diligence has been carried out. They must then inform the competent authorities and may only place the product on the market if the verification of the due diligence carried out shows that no risk or only a negligible risk has been identified. A 'concrete indication' is a substantiated claim based on objective and verifiable information. In the case of other relevant information, or if the downstream market participant or trader is an SME, they only need to inform the competent authorities.

Products within the scope

There is a minor adjustment to the products covered by the EUDR. Printed products have been removed from the scope. These include printed books, newspapers, images and other products of the printing industry, manuscripts, typescripts and plans on paper. All other basic products and derivatives listed in Annex I must still comply with the requirements of the EUDR.

Simplification review 

A new provision requires the Commission to carry out a simplification review of the EUDR by 30 April 2026. Based on that review, a report must be submitted to the Parliament and the Council accompanied by, where appropriate, a legislative proposal. 

What remains unchanged?

Primary operators that are medium-sized or large enterprises must still carry out full due diligence as set out in the EUDR. This due diligence consists of three steps: (i) gathering certain information; (ii) conducting a risk assessment based on the information gathered; and (iii) identifying measures to reduce any risks related to non-compliance to zero or negligible levels (see also our previous blog post). However, given the mandatory simplification review, this due diligence regime may still be amended in 2026 before the date of application.

Practical consequences

The amendments to the EUDR give companies additional time to comply with the EUDR by postponing the date of application. The amendments also significantly reduce the burden on micro and small primary operators in particular. Nevertheless, setting up an effective due diligence system takes time, and it is important that companies prepare for this and start doing so if they have not already done so, while also keeping an eye on any changes come spring when the Commission completes its review. 

The details of some of the specific steps expected of companies remain unclear. For example, it is unclear what downstream operators and traders should do in the period from 30 December 2026 to 30 June 2027 when they have to collect declaration identifiers (something that micro and small primary operators do not yet have to submit because the EUDR will apply to these companies at a later date). We hope that the Commission will provide clarification on these issues in the near future, for example by publishing a guidance document.