Deforestation under control, but wisely, or EUDR 2.0 in practice

EU anti-deforestation law has received its first amendment. "EUDR 2.0"—officially Regulation (EU) 2025/2650 of 19 December 2025—delays the effective date of the regulations and simplifies some requirements. These changes are a response to business concerns and implementation challenges, but do not mean a retreat from our ambition to protect forests.

Context of the introduction of EUDR 2.0

The EUDR 2023/1115 regulation was introduced in 2023, prohibiting the marketing of products linked to deforestation. Initially, large and medium-sized companies were supposed to begin complying with the requirements by the end of 2024, but the lack of ready-made tools (including an IT system for tracking deliveries) and difficulties in obtaining data from suppliers resulted in this deadline being postponed by a year, to December 2025. In 2025, businesses appealed for another postponement, but EU institutions chose a different path: maintaining the regulation's objective while facilitating its implementation. This is how the concept of EUDR 2.0 (Regulation 2025/2650) was born – an amendment to the original deforestation regulation introducing technical changes and extending the implementation timeline, which was ultimately adopted in December 2025.

New dates and more time to adjust

The most noticeable change is the postponement of the deadlines for applying the EUDR . Large and medium-sized enterprises must comply with the requirements only from December 30, 2026 , while small and micro-enterprises must comply from June 30, 2027. The additional 12 months are crucial: to allow for the completion of IT infrastructure preparation and the adaptation of procedures on the part of the administration and business.

In other words, companies were given more time to build supply traceability systems, collect data on the origin of raw materials and implement internal due diligence procedures to avoid operational paralysis and disruptions in supply chains.

Key changes in EUDR 2.0

The amendment introduces a number of simplifications to business obligations, simplifying procedures without changing the purpose of the regulation . Here are the most important changes:

• "First mover" instead of multiple declarations: Responsibility for submitting a due diligence declaration is now placed on the entity that first introduces the goods to the EU market (e.g., the importer of the raw material). This operator conducts full due diligence and submits the declaration in the EUDR system. Entities further down the supply chain (subsequent sellers, processors, retailers) are no longer required to submit their own declarations. Their role will be to ensure traceability by collecting information about suppliers and forwarding the reference number of the declaration (or simplified declaration) issued by the first operator. This approach eliminates duplication of bureaucracy and reduces the burden on the IT system, while maintaining control over the origin of the goods.

• Simplifications for the smallest producers: A new category of micro and small primary operators has been introduced – small producers (e.g., farmers) from low-risk countries who independently produce and market the covered goods. These micro and small operators are provided with a single, simplified declaration in the EUDR system, instead of a full declaration for each batch. This means that a small producer only has to submit data on their goods once, obtaining a declaration identifier that then accompanies their products. This solution significantly reduces costs and administrative barriers for the smallest suppliers – which is significant, as almost 100% of farmers in the EU are micro or small enterprises.

• Exclusion of printed products: Certain printed products (e.g., books, newspapers, and printed matter) have been excluded from the scope of the EUDR, as they are deemed to have a negligible impact on deforestation. This will help avoid disproportionate burdens on paper-using industries (publishing, printing).

It's worth emphasizing that the above modifications are administrative and procedural in nature – they do not change the fundamental requirement of zero tolerance for raw materials from deforested areas after 2020. The EU's climate and environmental ambitions remain intact, and the regulation is merely intended to become more user-friendly in practical implementation. Furthermore, the amendment obliges the European Commission to re-examine (review) the EUDR for further improvements by April 2026, meaning that the legislator will monitor the effects of these changes and propose further adjustments if necessary.

Impact on businesses

For companies operating in the EU, EUDR 2.0 brings some relief, but it also poses new requirements. Large and medium-sized enterprises have gained an extra year to prepare, so this time must be used effectively. By the end of 2026, every major player must have a fully functioning due diligence system for raw materials covered by the EUDR. In practice, this means detailed supply chain tracking, collecting data on the origin and geolocation of raw materials, and analyzing deforestation risk.

Companies that have already started implementing the EUDR should update their procedures and documentation (taking into account the new categories of entities and the changed scope of responsibilities).

Those who haven't yet started must begin implementing these initiatives immediately. Implementing a due diligence system and gathering comprehensive supplier data can take many months, and the key to ensuring continued supply once the regulations come into force is paramount.

Smaller enterprises (SMEs) have been granted a longer respite, until mid-2027, giving them more time to adapt. Additionally, the smallest farmers and producers in the EU and other low-risk countries will benefit from a simplified declaration instead of full reporting. However, in their case, it's worth not leaving preparations until the last minute. Even limited obligations require planning and education.

Non-EU companies exporting to the EU will also feel the impact of EUDR 2.0. Because full responsibility rests with the importer, exporters are not required to submit their own declarations, but they must provide their EU partners with complete data on the origin and legality of raw materials. For small farmers in developing countries (especially those at high risk of deforestation), the regulations remain a significant challenge. NGOs warn that without support, many of them could be excluded from the market. Therefore, it is recommended that European companies support small non-EU suppliers – for example, through training, providing crop tracking technology, or assistance with certification, which will facilitate compliance and maintain sustainable supply chain relationships.

Summary and recommendations for companies

The new version of the EU's anti-deforestation regulation is certainly an evolution, not a revolution . EUDR 2.0 simplifies implementation mechanisms and gives companies valuable time to adapt, but it doesn't change the fundamental direction: European supply chains are to be free of products contributing to forest destruction. For companies involved in ESG, compliance, procurement, and supply chain management, it's an opportunity to better prepare. It's worth:

• Don't delay: Take the extra year (or more for SMEs) to finalize all procedures. Assess your supply chains for deforestation risk, identify "weak links" (suppliers without data, high-risk countries), and implement a remediation plan where information or compliance is lacking.

• Invest in tools and data: Meeting EUDR requirements requires robust data (e.g., plantation geolocation, proof of legality). It's worth investing in IT systems to manage supplier data and integrate with the EU's EUDR system. Modern tools, including satellite monitoring, will help track the origin of raw materials.

• Collaborate within the industry: Not all EUDR challenges can be solved by a company alone. Therefore, it's worth collaborating within the industry – sharing supplier data and developing common standards and best practices. Such cooperation will make it easier for everyone to adapt to the new requirements.

• Review contracts and procedures: Update internal documentation and supplier contracts (incorporate new categories and obligations) and add clauses requiring suppliers to submit data and comply with EUDR requirements.

• Monitor further regulatory changes: The EUDR implementation process will be monitored by EU institutions. The announced review in 2026 may bring further modifications – companies should follow European Commission announcements and respond to any new guidelines or obligations.

EUDR 2.0 is certainly a simplification, not a retreat. Businesses are given simpler rules and time to prepare, but the goal remains the same: to stop global deforestation through responsible supply chains . Companies that rise to the challenge and comply with the requirements now will not only avoid sanctions but also gain a competitive advantage in a demanding market.