EUDR Status Update – The Original Timeline Holds With Proposed Changes to the Requirements
The European Commission has announced that it will not propose a postponement of the EU Deforestation Regulation for large or medium-sized companies – meaning the regulation will still apply at the end of 2025. However, the Commission is proposing amendments to the regulation’s content to reduce reporting requirements for certain operators and ease the workload on the TRACES information system.
On 21 October 2025, the European Commission released a document providing clarifications on the timeline and content of the EU Deforestation Regulation (EUDR). The aim is to refine certain definitions and reduce reporting requirements in order to ease the burden on the TRACES information system and simplify the implementation of the regulation. The proposal still requires the formal approval of the European Parliament and the Council of the EU before it can enter into force.
Timeline
The Commission does not propose a full-on postponement of the EUDR’s application but adjusts the timeline based on company size and position in the supply chain:
- Large and medium-sized enterprises: The EUDR will apply as originally planned from 30 December 2025, but a six-month grace period will apply to allow for a gradual phase-in of the rules. During this period, no penalties or sanctions will be imposed for non-compliance.
- Micro and small enterprises: The EUDR will apply from 30 December 2026, six months later than initially planned.
New definitions
To clarify the regulation’s definitions and ease reporting obligations for certain operators, the Commission proposes introducing two new operator categories: downstream operators, and micro & small primary operators.
Downstream operators
- “Downstream operators” are companies that do not place products on the EU market directly from producers but instead purchase EUDR-relevant products already available on the EU market and carry out further activities with them (e.g. resale, assembly, distribution).
- Their obligations are aligned with those of traders. Both groups will no longer be required to prepare or submit a due diligence statement (DDS), nor to verify that the previous stage in the supply chain has carried out a due diligence assessment.
- Large downstream operators and traders will still be required to register in the EUDR information system, given their significant influence on the supply chain and responsibility to ensure that products placed on the market are deforestation-free.
- All operators, including SMEs and smaller entities, must continue to ensure full traceability, collecting and transmitting relevant reference numbers and declaration identifiers for all products.
Micro and small primary operators
- This new category covers small & micro operators that themselves produce relevant commodities (e.g. grow, raise, or harvest them) and are established in a low-risk country.
- These operators will be exempt from the obligation to submit a due diligence statement. Instead, they must provide a simplified one-off notification containing basic information about their activities and production sites (e.g. geolocation or address), which can also be submitted through a national system.
- Upon submission, operators will receive a declaration identifier, which must be attached to all products placed on the market.
Conclusions and Bluugo’s recommendations
The Commission’s proposal can be interpreted in various ways depending on what operator category a company belongs to, but the central message is that the overall timeline remains unchanged, except for micro and small enterprises. The regulation will enter into application on 30 December 2025, in about two months’ time – leaving little room for delay for companies still finalizing their EUDR preparations.
The proposed six-month grace period will offer some leeway for latecomers, as no sanctions will be imposed during the first half of 2026, even if the compliance procedures are not yet perfect. Nevertheless, now is the final moment to act to ensure EUDR compliance by the end of June 2026.
For certain companies, the reduction in reporting requirements may come as a welcome relief, as it removes the obligation to create due diligence statements (DDS). However, these companies will still need to ensure that the original DDS information flows through the entire value chain to the final products – meaning that the need for traceability solutions does not disappear under the new proposal. Companies must continue to invest in supply chain transparency and seamless data exchange between stakeholders to ensure compliance with both the current and upcoming regulation.
For micro and small enterprises, the requirements will only apply from 30 December 2026, but it is important to note that larger entities such as wholesalers and retail chains will still require all necessary DDS data from their suppliers according to the original schedule. Therefore, even if the EUDR obligations do not yet formally apply to some companies, larger partners are likely to start requesting this information as early as the beginning of 2026.
If your company needs support with EUDR compliance, don’t hesitate to contact us. Our Tracking Cloud® EUDR solution package provides all the necessary tools to ensure compliance with the regulation. The solution can be deployed quickly and adapted easily to any future changes.
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