On Wednesday, November 19, 2025, the Committee of Permanent Representatives of the Council of the European Union (COREPER) adopted a negotiating mandate for the next revision of the Deforestation-Free Regulation (EUDR). This decision introduces a further delay in the regulation's implementation and significant simplifications to due diligence procedures, which could significantly impact how companies will demonstrate compliance with the requirements.
Chronology of events: third delay in a short time
Regulation (EU) 2023/1115 on the making available on the Union market and the export from the Union of certain goods and products related to deforestation and forest degradation entered into force on 29 June 2023. The regulations were originally scheduled to apply on 30 December 2024 for large and medium-sized enterprises and on 30 June 2026 for micro and small enterprises.
However, in December 2024, in response to signals about the lack of readiness of businesses and administrations, the European Parliament and the Council adopted Regulation (EU) 2024/3234, which delayed the entry into force of the main provisions by one year – until 30 December 2025 (for large and medium-sized enterprises) and 30 June 2026 (for small and micro enterprises).
In September 2025, the European Commission signaled the need for another delay, citing the insufficient readiness of IT systems to handle the expected number of due diligence statements (DDS). In October 2025, the Commission officially presented legislative proposal COM(2025) 652 final, which provided for a six-month grace period for large companies while maintaining the December 30, 2025 deadline, as well as additional procedural simplifications.
COREPER decision of 19 November 2025: key changes
According to the official press release of the Council of the EU of 19 November 2025, COREPER adopted a negotiating mandate that introduces significant modifications to the Commission's initial proposal.
1. Uniform delay of one year for all
The EU Council rejected the concept of a “grace period” proposed by the Commission and opted for a clear, uniform delay in the application of the regulation:
- December 30, 2026 – for medium and large operators
- June 30 2027 – for micro and small enterprises
This solution aims to provide legal clarity and avoid situations where regulations are formally in force but are not enforced for a certain period.
2. Simplifying due diligence procedures
The most significant procedural change is the radical simplification of the chain of responsibility for submitting due diligence declarations (DDS):
New rules:
- Just first operator introducing the product to the EU market will be obliged to issue and submit a DDS declaration
- Operators further down the supply chain (downstream operators) and traders (traders) will not have to submit their own DDS statements
- Subsequent participants in the supply chain will only be obliged to storing and transmitting the reference number original DDS statement
For micro and small primary operators: An additional facility has been introduced – they will only submit one-time simplified declaration, which is expected to significantly reduce the administrative burden for the smallest producers.
3. Commitment to review and further simplification
The EU Council has committed the European Commission to carry out, by April 30 2026 year, a comprehensive simplification review, which will assess:
- The impact of the EUDR on operators, with particular emphasis on micro and small enterprises
- Administrative burdens resulting from the regulation
- Possibilities for further simplifications
If necessary, this review should be supplemented by a legislative proposal introducing additional simplifications.
Member States' positions: a divided Union
While official EU Council documents do not publish detailed voting results for individual countries, industry and diplomatic reports suggest that member states were divided.
Supporters of a strong EUDR ("Champions"), including France, Spain, Belgium, and the Netherlands, initially opposed further delays, fearing they would weaken the regulation's environmental ambitions. Germany, initially hesitant, ultimately supported the proposed delay.
Critics of the EUDR, including Sweden, Hungary, Austria and the Baltic states, have consistently demanded further simplifications and the introduction of a review clause that would allow for the reopening and modification of the regulations.
Ultimately, the compromise proposal of the Danish Presidency of the Council of the EU gained the support of the majority of member states, enabling the adoption of the negotiating mandate.
What does this mean for businesses?
Immediate implications
1. More time to prepare Companies that haven't had time to prepare for the December 2025 deadline will gain an extra year. However, companies that have already invested in compliance systems can view this additional time as an opportunity to refine procedures and test solutions.
2. Simplified responsibility model The new “one DDS per supply chain” model means that:
- Importers and first movers on the EU market will have a key role and responsibility
- Producers, retailers and intermediaries further down the chain will have a much lower administrative burden
- It will be crucial to ensure the DDS reference number is traceable throughout the supply chain.
3. Changes in IT systems Companies that have already implemented or are planning to implement DDS claim management systems may need to adapt them to the new model, where most operators only manage reference numbers rather than full claims.
Strategic Questions for Businesses
Businesses should now ask themselves some key questions:
Are you the first operator to introduce a product to the EU market? If so, your responsibility will be paramount. You must ensure complete due diligence, including geolocation of plots, verification of compliance with the laws of the country of production, and confirmation of no deforestation after December 31, 2020.
Are you further along in the supply chain? If so, your responsibilities will be significantly simplified – you will only need to store and forward the DDS reference number from your first operator.
Are you a micro or small start-up enterprise? The new regulations provide special facilities for you in the form of a one-time simplified declaration.
Should you continue preparations despite the delay? Yes. Although the deadline has been extended, the key elements of the EUDR remain unchanged. Companies that use this time to prepare thoroughly will gain a competitive advantage and avoid legal risks once the regulations enter into force.
Next legislative steps: uncertainty remains
COREPER's decision is just the beginning of the legislative process. For the changes to come into effect, they must be approved by:
1. European Parliament The EP is expected to vote during its plenary session in Strasbourg from November 24-27, 2025. The Parliament previously voted to delay the EUDR on November 14, 2024, but also introduced controversial amendments, including the creation of a new category of "no risk" countries, which was criticized by environmental groups and rejected by the Council.
2. Trilateral negotiations (trilogue) Following the EP vote, intensive negotiations will begin between the Parliament, the Council, and the Commission. The first trilogue is scheduled for early December 2025.
3. Formal adoption and publication For the changes to enter into force by the current deadline of 30 December 2025, the final text must be adopted, signed, and published in the EU's Official Journal before the end of the year. This is a very tight timetable that puts a lot of pressure on all institutions.
Risk: If an agreement is not reached before 30 December 2025, the EUDR will formally enter into force on the original, undelayed date, creating legal and operational chaos.
Controversy: Does another delay weaken the EUDR?
The decision to delay the EUDR for the third time was met with mixed reactions.
Environmental organizations, including WWF and Fern, have sharply criticized the further extension of deadlines. Anke Schulmeister-Oldenhove of WWF's European Policy Office stated that "delaying the application by even one year already risks exacerbating global deforestation. Any additional delays and weakening would lead to further destruction, with devastating consequences for forests, climate, and biodiversity."
Some industry groups, particularly companies that have already invested significantly in compliance (such as Ferrero and Nestlé), have also expressed frustration. They argue that further delays create uncertainty, undermine the EU's credibility as a regulator, and demotivate companies that have acted in good faith.
On the other hand, a significant part of the industry welcomed the delay as necessary, pointing to real technical problems with the IT system and insufficient preparedness of smaller operators, especially in third countries.
The Wider Context: EUDR in the Era of "Cutting the Bureaucratic Tape"
The decision to delay and simplify the EUDR is part of a broader trend in the European Union. Under pressure from industry and some member states, the European Commission, led by Ursula von der Leyen, launched the "Omnibus I" initiative, aimed at reducing the administrative burden associated with ESG regulations.
The Commission has announced that the proposed simplifications to the EUDR will reduce administrative burdens for businesses by around 30%. However, critics warn that the fundamental environmental objectives underlying the EUDR should not be undermined in the name of "cutting red tape."
Impact on international trade and relations with third countries
The EUDR has a significant impact on the EU's trading partners. Countries producing goods covered by the regulation—such as Brazil, Indonesia, Malaysia, and Ghana—have repeatedly expressed concerns about the regulation's requirements and their impact on local producers.
Discussions surrounding the recently concluded trade agreement between the EU and Mercosur (Argentina, Brazil, Paraguay, and Uruguay) are particularly controversial. Studies suggest that this agreement could increase deforestation in Mercosur countries by at least 25% annually for the next six years, directly contradicting the EUDR's objectives.
Summary: What's next for EUDR?
The COREPER decision of 19 November 2025 marks another chapter in the turbulent history of the EUDR. The introduction of a uniform one-year delay and significant simplification of due diligence procedures represents an attempt to strike a balance between environmental ambitions and implementation realities.
Key takeaways for businesses:
- Don't underestimate the delay if it comes into force, because the EUDR will come into force and companies prepared in advance will gain a competitive advantage
- Understand your position in the supply chain – Your responsibilities will be radically different depending on whether you are the first operator or further down the chain
- Monitor the development of the situation – the final shape of the regulations will be known only after the trilogue is completed, probably in December 2025
- Prepare for the 2026 review – The Commission will evaluate the functioning of the EUDR after only four months of enforcement, which may bring further changes
Despite all the delays and controversies, the EUDR remains one of the most ambitious environmental regulations in EU history. Its final shape and effectiveness will be fundamental not only for global forest protection but also for the European Union's credibility as a leader in global climate policy.
Sources and legal basis:
- Regulation (EU) 2023/1115 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 goods and products related to deforestation and forest degradation (OJ L 150, 9.6.2023)
- COM (2025) 652 final – European Commission proposal of 21 October 2025 for targeted changes to the EUDR
- EU Council press release of 19 November 2025 – “Deforestation: Council ready to start talks with Parliament on a targeted revision of the regulation” Link: https://www.consilium.europa.eu/en/press/press-releases/2025/11/19/deforestation-council-ready-to-start-talks-with-parliament-on-a-targeted-revision-of-the-regulation/
- Council document 14682/25 (available in the public register of EU Council documents)
- European Commission Guidance Note regarding the implementation of the EUDR (update November 2025)
