LEGAL ALERT: Postponement of the application of the EUDR provisions and proposed simplifications to the due diligence procedure
On November 26, 2025, the European Parliament supported the draft amendments to the EUDR. The proposed changes mainly include a 12-month postponement of the application of the provisions and a modification of the scope of obligations related to the due diligence procedure.
What is the EUDR?
The EUDR (EU Deforestation Regulation) is Regulation (EU) 2023/1115 of the European Parliament and of the Council on the placing on the Union market and export from the Union of certain goods and products related to deforestation and forest degradation and repealing Regulation (EU) No. 995/2010. The Regulation prohibits the placing on the market, making available on the market, or exporting from the market of products and goods covered by the Regulation, unless:
- they do not cause deforestation;
- they have been produced in accordance with the relevant regulations of the country of production;
- a due diligence statement has been submitted in their regard.
The Regulation covers commodities such as cattle, cocoa, coffee, soybeans, rubber, timber, and palm oil, which are referred to as “”relevant commodities.“ In addition, the provisions of the Regulation also cover products derived from the above-mentioned raw materials, referred to as ”relevant products.”
What do the amendments voted by the European Parliament entail?
The European Parliament has endorsed a package of amendments to align the pace of implementation of the EUDR with the actual capabilities of administrations and economic operators. The amendments include both an update of the implementation schedule and simplifications to the due diligence procedure.
- Change in the date of application of the EUDR provisions
The most important change is the postponement of the application of the EUDR provisions by 12 months
According to the position voted by the European Parliament, large and medium-sized enterprises will be required to apply the provisions from December 30, 2026, while small and micro-enterprises will only be required to do so from June 30, 2027.
The postponement is intended to ensure the stability of the IT system (used for submitting due diligence declarations) and to adapt administrative procedures in Member States. The change in the deadline will also give businesses time to adapt their internal procedures, avoiding potential disruptions in the supply chain.
Simplifications in the due diligence obligation
The second pillar of the approved package of changes consists of solutions aimed at simplifying and making the application of due diligence procedures more realistic. The most important solutions are to include:
- focusing responsibility on the first introducer
the obligation to submit a due diligence declaration shall rest with the entity that first places a product covered by the EUDR on the EU market. Entities further down the supply chain will be largely exempt from repeating the same obligations and will be able to rely on the declaration of the first operator;
- simplified declaration for micro and small businesses
According to the proposal, micro and small businesses will be subject to a one-time, simplified declaration instead of full due diligence procedures for each batch of goods. This solution is intended to significantly reduce the barrier to entry and administrative costs for the smallest entities.
- European Commission’s commitment to review the EUDR
The Parliament has committed the European Commission to analyze the impact of the EUDR on businesses and the level of administrative burdens by April 30, 2026. The outcome of the review may form the basis for further legislative adjustments.
Is the change already in force? What else needs to happen?
The adoption of the package of amendments by the European Parliament does not automatically mean that the new provisions will enter into force, although it is an important step in the overall legislative process.
For the postponement and planned simplification to become legally effective, the following is necessary:
- agreement on the final wording of the amendment during tripartite negotiations between the European Parliament, the Council of the European Union, and the European Commission;
- formal adoption of the legal act by the European Parliament and the Council of the EU;
- signing of the regulation by the presidents of both institutions;
- publication of the amendment in the Official Journal of the European Union
How can we help?
Our law firm offers comprehensive legal support for entrepreneurs preparing to implement the provisions of the EUDR. The scope of our assistance includes, among other things, analysis of legal obligations and ongoing advice on the practical application of the provisions. We also support companies in the development and implementation of due diligence procedures.
If you are interested in obtaining additional information in this regard, please contact us.
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