EUDR – agreement to postpone start of application

Industry and trade in Europe have been closely following the trilogue negotiations between the European Parliament, the Council of the European Union and the European Commission on the amendment of the Deforestation Regulation (EU) 2023/1115 (“EUDR”). The Council of the European Union and the European Parliament have now agreed to revise the EUDR, aiming to simplify how the existing rules are implemented and to postpone their application so that companies and authorities have more time to prepare.

Since it entered into force in June 2023, the EUDR has faced strong criticism and its application has already been postponed once. The regulation seeks to ensure that placing products made from certain commodities (cattle, cocoa, coffee, palm oil, rubber, soya and timber) on the market does not contribute to deforestation. It was originally due to start applying from 30 December 2025.

In October 2025 the European Commission put forward a proposal to amend the EUDR, officially citing technical problems in setting up the IT system for due diligence statements (see EUDR only to be postponed for small enterprises, but simplifications planned for traders). The key issue was the much-discussed “grace period”, a planned six-month suspension of enforcement for large and medium-sized companies, while micro and small-sized enterprises were to see the start of application pushed back by a further year.

The Council responded to this initiative by the Commission with a significantly more far-reaching position. Instead of endorsing a short transition period, it called for a broad postponement of the application duties (Council mandate to amend the EUDR – Will a general postponement prevail?). In the meantime, the Council appears to have largely prevailed in the trilogue. On 4 December 2024, the Council and Parliament agreed on the following points:

Postponement of application

• The regulation will apply to all companies only from 30 December 2026 onwards.
• Micro and small-sized enterprises gain an additional six-month postponement.

First-touch principle

• In future, only those operators who first place the relevant product on the market will be responsible for submitting due diligence statements.
• Downstream companies will only have to store the reference number of the original statement and will no longer need to pass data along the supply chain.
• Micro and small-sized enterprises will be required to submit a simplified statement only once and will receive an identification number for traceability purposes.

Adjustment of the relevant products covered

• Certain printed matter (e.g. books, newspapers) are to be removed from the scope of application of the regulation.

IT system, monitoring and evaluation

• Member States must report significant system disruptions to the Commission and regular exchanges with stakeholders will remain mandatory.
• The Commission is to submit a report on simplification by April 2026, possibly accompanied by legislative proposals.

Next steps:

The European Parliament will vote on the joint position on 16 December 2025. The Council must then formally confirm the agreement. Once the amending act has been published in the Official Journal, the changes will enter into force. This must be done before the end of the year – otherwise, the EUDR will apply in its unchanged form to large and medium-sized enterprises from 30 December 2025. Last year, publication took place on 23 December 2025, so despite the year-end there is still sufficient time. For companies now going through this “nail-biting” process for a second time, however, that is only limited consolation.