The regulation is scheduled (after a previous one-year delay) to apply from 30 December 2025 for large and medium-sized enterprises, with micro and small operators facing later deadlines.  However, practical challenges — such as IT system readiness and administrative burdens — prompted the European Commission (the Commission) to consider a further one-year delay to the EUDR’s implementation. 

However, on 21 October 2025, the Commission instead proposed a number of ‘targeted’ simplification amendments to the EUDR, both to ease the administrative burden on in-scope companies and to help ensure that the EU’s IT infrastructure is able to cope as the EUDR takes effect.  This simplification proposal follows, and indeed explicitly references, Mario Draghi’s 2024 report on the future of European competitiveness which identified the ever-increasing administrative burden on businesses operating in the EU. 

The most important element of the proposal is that the Commission confirmed that the 30 December 2025 commencement date remains in place for large and medium-sized operators (despite the speculation about a possible one-year delay).

Below, we set out key proposed amendments.

Key proposals announced in October 2025

• • A new formal category of ‘downstream operators’ is established.  These operators, who ‘commercialise’ (i.e. sell) relevant products and who will have the same new reduced obligations as traders, will no longer need to submit separate due diligence statements (DDS), nor will they need to ascertain that due diligence has been undertaken.  Responsibility for DDS will rest with the upstream operator placing the product on the EU market for the first time. Downstream actors must still retain and forward DDS reference numbers.
  • A new formal category of ‘micro and small primary operators’ is established.  These are operators from low-risk countries who only supply or export relevant products which they themselves produce.  They will only need to submit a single simplified declaration in the EUDR IT system. Where relevant data exists in a national EU Member State database, that will also be sufficient. These obligations will apply from 30 December 2026.
  • Enforcement measures under Articles 16 to 19, 22 and 24 for other undertakings will be deferred until 30 June 2026. Until then, authorities may issue warnings and recommendations rather than penalties for non-compliance.  Importantly, however, this does not apply to customs checks under Article 26 (which, under the proposal as currently drafted, will still apply from 30 December 2025). 

A general review of the EUDR is now scheduled for 30 June 2030, during which the impact of these amendments will also be assessed. 

Next steps

The proposed amendments – which, it is important to emphasise, are not yet law – still require approval by the European Parliament and Council before they take effect.  

The Commission has stated that it expects agreement to be reached before year-end, but that it is preparing contingency plans should delays occur.  Given that the EUDR will, as things stand, take effect on 30 December 2025, this timing is obviously very tight.  It also still leaves in-scope companies facing great uncertainty.