Contrary to earlier announcements by the European Commission, which in October declared that there would be no further postponement of the EUDR, the European Parliament, during its plenary session on 26 November 2025, adopted by a substantial majority (402 in favour, 250 against, 8 abstentions) a package of amendments to Regulation (EU) 2023/1115 on deforestation-free products (EUDR). The aim of the amendment is not only to simplify obligations, but also to provide all businesses – both within and outside the EU – with an additional year to prepare for the new requirements. The legislative process is still ongoing. The proposal will now proceed to trilogue negotiations between the Parliament, the Council and the European Commission, where the final wording of the provisions will be determined.
One-year postponement of EUDR obligations – new implementation timeline
According to the position adopted by the European Parliament on 26 November this year, large and medium-sized enterprises will be required to comply with the obligations under the EUDR only as of 30 December 2026, while micro and small enterprises will become subject to the new requirements as of 30 June 2027. This additional year is intended not only to allow for a smoother adaptation of internal processes and procedures, but above all to enable further development and optimisation of the EU IT system for the submission of due diligence statements (DDS). The revised timeline marks a significant change from the European Commission’s October proposal, which provided for the existing dates (30 December 2025 for large and medium-sized enterprises, with a six-month transitional period, and 30 December 2026 for micro and small enterprises).
Following the changes approved by the European Parliament, the timeline for the commencement of application of the EUDR is now as follows:
Entity type | Date of entry into force of the EUDR provisions |
|---|---|
Medium-sized and large enterprises | 30 December 2026 (without transitional period) |
Micro and small enterprises | 30 June 2027 |
Key simplifications of obligations – what has changed?
The European Parliament has clearly opted for further deregulation of obligations and a reduction of bureaucracy, including:
- Reduction of obligations in the supply chain:
The obligation to submit due diligence statements (DDS) will rest solely with the operator who first places the relevant product on the EU market. Subsequent actors in the supply chain – primarily traders – will be exempted from submitting their own DDS. The obligation to ensure traceability will be limited mainly to the first downstream operator, rather than all further supply chain participants.
- Abolition of the obligation to transfer DDS numbers down the chain:
The obligation to transfer DDS reference numbers and simplified declaration identifiers will apply exclusively to operators introducing relevant products to the market for the first time.
- One-off simplified declaration:
Micro and small primary operators will be exempted from submitting DDS for each transaction, and will instead be required to submit a one-off simplified declaration. This declaration will remain valid as long as there are no material changes in the product or producer data. Updates to the declaration will be required only in the event of significant changes. Where the operator makes use of a national database, data may be transferred directly to the EU system – in such cases, obtaining a declaration identifier will be sufficient.
- New approach to geolocation:
Micro and small primary operators may indicate only the postal address of all plots or facilities from which the relevant commodities contained in the relevant products or used in their manufacture originate, instead of providing detailed geographical coordinates of plots or plantations as required under the EUDR.
- Exclusion of books and newspapers from the scope of EUDR:
Annex I to the EUDR has been amended to remove code ex 49 – books, newspapers, pictures and other printed products of the printing industry, manuscripts, typescripts, and plans, on paper.
- Review of the impact of the EUDR regulations by 30 April 2026:.
Pursuant to the provisions adopted by Parliament, a detailed simplification review of the new regulations and assessment of the administrative burden is to be carried out by 30 April 2026. This is a separate procedure from the comprehensive review of the functioning of the EUDR, which the Council of the European Union has tentatively scheduled for 30 June 2030.
It should be emphasised that, during the vote, Members of the European Parliament rejected a number of amendments that would have significantly altered the scope of EUDR obligations – in particular, the proposal to introduce a new category of “no-risk” countries (which would be exempted from due diligence obligations and required only to meet documentation requirements) and the proposal to exclude leather (ex 4101, ex 4104, ex 4107) from the material scope of the EUDR.
EUDR – scope, objectives and obligations for businesses
As a recall - the EUDR entered into force on 29 June 2023 and covers the import into or export from the EU of relevant products containing or manufactured from relevant commodities: cattle, cocoa, coffee, oil palm, soya, rubber and wood, produced after the date of entry into force of the Regulation. The EUDR imposes a number of new obligations on businesses, in particular the requirement to exercise due diligence (including information gathering, risk assessment and risk mitigation) as well as to ensure full traceability of the origin of relevant products. The objective of the Regulation is to reduce deforestation and forest degradation, with a view to combating climate change and biodiversity loss. According to the initial assumptions, the obligations arising from the Regulation were to apply to all entities in the supply chain of relevant products, which would require appropriate preparation of IT systems, as well as internal reorganisation of business processes and supply chains – for which, according to industry statements, businesses were not fully prepared.
In response to these concerns, the Commission proposed a number of amendments and simplifications, aiming to ensure a smooth implementation of the new requirements and to enable operators and traders to adapt to their obligations, in particular by implementing and strengthening IT systems for the submission of DDS.
What happens next?
The adoption of the package of amendments by the European Parliament does not yet mean that the new provisions will enter into force. The text will now be subject to trilogue negotiations (European Commission – Council of the EU – European Parliament), the aim of which is to reach a final agreement on, and formally adopt, the provisions before the end of the year. Nevertheless, due to the high degree of alignment between the positions of the EU institutions, it is highly likely that the changes (in particular the further postponement of EUDR obligations) will be adopted in the proposed wording before year-end.
Scope of Client support
The KPMG Law team assists businesses at every stage of implementing new obligations arising under the EUDR. Our services include, among others:
- Review and clarification of the current regulatory requirements in the context of your operations.
- Support in the preparation and updating of procedures related to the submission of DDS.
- Assistance in identifying products and processes covered by the new regulations.
In addition, we continuously monitor legislative developments and the evolving practices of supervisory authorities, enabling us to provide tailored, up-to-date recommendations for optimal solutions suited to your company’s profile.
1Regulation (EU) 2023/1115 of the European Parliament and of the Council of 31 May 2023 on the making available on the Union market and the export from the Union of certain commodities and products associated with deforestation and forest degradation and repealing Regulation (EU) No 995/2010 (Text with EEA relevance).
