EU Deforestation Regulation - Delay Update
Environmental
29 January 2026
Summary of EU Deforestation Regulation
Region: Europe
Status: Amendment under review - (review on the minor and targeted substantive adjustments and not on its core objective)
Introduction
Regulation (EU) 2025/2650, published on 23 December 2025, amends the existing EU Deforestation Regulation (Regulation (EU) 2023/1115 – “EUDR”) to simplify compliance requirements for operators and traders and postpone key application deadlines. The amendments aim to reduce administrative burdens for businesses and improve the practical implementation of due diligence obligations while maintaining the regulation’s overarching objective of preventing deforestation and forest degradation associated with EU market consumption and exports.
Summary
Regulation (EU) 2025/2650 introduces several targeted amendments to the EUDR framework. The most notable changes include (excerpt taken from ECA circulation):
A 1-year delay, moving the date of application to 30 December 2026 for all operators (except micro- and small sized and all downstream operators. For micro- and small sized operators, the date of application is moved to 30 June 2027.
A removal of due diligence obligations for downstream operators. These will no longer have to ascertain that due diligence was carried out, nor will they have to submit a Due Diligence Statement (DDS).
A limitation to the sharing of the DDS to the first downstream operator (Operator+1). Downstream operators and traders will have to collect contact details of their suppliers, and only the first downstream operator would have to collect a DDS from its supplier if that is a first operator).
The insertion of a review clause for April 2026, instructing the European Commission to present a report to the European Parliament and Council outlining how it aims to simplify the EUDR from a perspective of lowering administrative burden. This review clause does not contain an obligation on the Commission to re-open the EUDR through a legislative proposal, revisions to Guidance & FAQ, and the upcoming delegated act to remove samples from the scope can also be deemed by the Commission to be suitable options.
Scope & Applicability
a. Scope of Regulation
The amending Regulation applies to the system of due diligence established under the EUDR for relevant commodities and products associated with deforestation and forest degradation (including cocoa, coffee, palm oil, soy, timber, rubber, cattle, and derived products). It applies to economic operators and traders placing these products on the EU market or exporting them.
b. New Categories & Definitions
Operator: Natural or legal person who, in the course of commercial activity, places relevant products on the market or exports them. Downstream operators are explicitly excluded from this definition.
Downstream Operator: New category for persons placing on the market products made from relevant products already covered by due diligence or simplified declarations. This category has simplified reporting obligations compared to primary operators.
Micro or Small Primary Operator: A specific subset of operators that may qualify for a one-time simplified declaration, especially in low-risk countries, replacing full geodata requirements under certain conditions.
c. Product Scope Adjustment
Certain printed products (books, newspapers, manuscripts, typescripts, and other printed matter under Chapter 49 of the Combined Nomenclature) are removed from the EUDR’s scope under Annex I following the amendment.
Key Requirements
a. Postponement of Compliance Deadlines
The application of key EUDR obligations for operators, traders, and competent authorities is postponed by 12 months to allow sufficient preparation time for businesses and Member States.
Revised timelines include:
Large and medium-sized operators and traders: Application from 30 December 2026.
Micro and small enterprises: Application from 30 June 2027.
b. Simplified Due Diligence Reporting
Under the amended regime:
Only the operator placing a product on the EU market for the first time is required to conduct full due diligence and submit a due diligence statement.
Downstream operators and traders no longer need to submit separate due diligence statements for products already placed on the market and covered by an existing due diligence declaration — they must instead collect and retain information, including references to the original due diligence statement.
c. Simplified Declaration for Certain Operators
Micro and small primary operators may submit a one-off simplified declaration instead of standard due diligence, with flexibility to provide postal addresses instead of geolocation coordinates in some situations.
d. Commission Review Obligations
The Commission is required to conduct a simplification review by 30 April 2026 to assess the administrative burdens on stakeholders, with the possibility of proposing further legislative or technical measures.
Compliance Deadline
The amended Regulation clarifies and extends the timeline for regulatory compliance under the EUDR to allow businesses, Member States, and non-EU supply chain partners adequate time for preparedness:
30 December 2026: For medium and large operators and traders to fully comply with due diligence and reporting obligations.
30 June 2027: For micro and small operators to comply with applicable simplified obligations.
These deadlines mark a 12-month extension from the prior dates applicable under the original EUDR framework.
Downloadable Resources