Key takeaways
Delay to application timeframe
The provisional agreement removes the six month “grace period” initially proposed by the Commission for large and medium companies. All businesses will have one more year to comply with the EUDR as follows:
- Large and medium operators and traders: the EUDR will apply from 30 December 2026.
- Micro and small operators: the EUDR will apply from 30 June 2027.
Simplification of due diligence obligations
Under the provisional agreement, responsibility for submitting a due diligence statement (DDS) is limited to operators first placing a relevant product on the EU market, meaning that there will be no requirement for downstream operators or traders to submit a DDS. Additionally, the obligation for all operators and traders to pass DDS reference numbers down the supply chain, as set out in the Commission’s initial simplification proposals, has been removed such that only the first downstream operator in the supply chain must collect and retain the reference number of the initial DDS.
In keeping with the Commission’s proposals, the provisional agreement also provides that micro and small primary operators will only have to submit a one-off simplified declaration in the EUDR IT system, replacing the previous requirement for DDS submissions for these entities.
Review of the EUDR
The European Commission has been tasked by both co-legislators with conducting a simplification review and presenting a report by 30 April 2026 to assess the administrative burden of the EUDR, particularly for smaller operators. The report should indicate ways to address the identified issues, including through guidelines and improvements to the information system and, where appropriate, be accompanied by a legislative proposal.
Amendments to scope
Under the provisional agreement, certain printed products (such as books, newspapers and printed materials) have been removed from the EUDR scope. The Council has confirmed that this reflects the limited deforestation risk associated with these items.
Next steps
The European Parliament and the Council must formally adopt the provisional agreement before it can come into effect. It is expected that the European Parliament will vote on the deal during its 15-18 December 2025 plenary session. The agreed text must then be published in the EU’s Official Journal before the end of 2025 for the changes to enter into force.
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