EU Commission changes course on EUDR

In a surprise move, the EU Commission changed its plans regarding the EU's Deforestation Regulation (EUDR)…again.

According to news reports, the EU Commission had previously proposed delaying the EUDR for an additional year at the end of September. On October 21, 2025, the Commission proposed a different approach to address IT issues as well as to reduce the bureaucratic burden for those market participants that need to comply with the EUDR.

The Commission proposes reducing the obligations for:

• Operators and traders that commercialize EUDR products that have already been placed on the EU market, and
• Micro and small primary operators from certain countries who sell their goods directly on the European market.

Further, the Commission proposes transitional periods to strengthen the IT system. The EUDR is supposed to enter into application on December 30, 2026 for micro and small companies. While the date remains December 30, 2025 for large and medium companies, they are supposed to benefit from a grace period of six months.

By no longer requiring downstream operators and traders to submit due diligence statements, the Commission not only reduces bureaucratic burden but also reduces the pressure on its IT system. This pressure was the main reason for proposing the delay late last month. By limiting the paperwork to be done by micro and small primary operators selling directly on the European market, the Commission is apparently responding to the renewed pressure for a “no-risk category” — in particular for farmers and forest owners in the EU.  

The new transitional periods proposed by the Commission should not only help the IT system, but should also cause relief for many market participants.

Before the changes proposed by the European Commission become law, the European Parliament and the Council will have to agree to the changes as well. A fast-track proceeding in the European Parliament will be required in order to make sure that the required legislative steps can be taken before the end of this year.