On 21 October 2025, the European Commission announced a key proposal for changes to the implementation of the regulation EUDR (EU Deforestation Regulation), an EU act that aims to ensure that goods entering the EU market do not contribute to deforestation or forest degradation. The latest Commission communication (IP / 25/2464) is of strategic importance for both large importers and small producers and traders throughout the supply chain.
Why is the Commission introducing changes?
According to the original timeline, the EUDR was to become applicable on 30 December 2025 for large companies and on June 2026 for micro and small enterprises. However, an analysis of technical readiness and the number of expected transactions in the EUDR Information System (TRACES) revealed that the IT infrastructure was at risk of overload. The system, which is expected to handle millions of due diligence declarations, requires additional time for stabilization and testing.
The Commission therefore proposed targeted solutions, which are intended to facilitate the implementation of regulations and reduce the risk of administrative paralysis. The priority now is efficiency and feasibility, not the quick entry into force of the regulations.
The most important proposals for change
1. One statement for the entire supply chain
Until now, the regulation assumed that each entity in the supply chain – from importer to end-manufacturer – had to submit its own due diligence declaration (DDS). The Commission is proposing a simplification:
First operator only (e.g. an importer of coffee beans, timber or cocoa) will be responsible for submitting a declaration in the system.
Further downstream participants (e.g., chocolate, furniture, or paper producers) will be able to refer to this single, original declaration. This will significantly reduce duplicate reporting and simplify administration for thousands of European companies.
2. Simplifications for micro and small enterprises
For micro and small operators from low-risk countries, the Commission is planning a simple, one-time declaration in the IT system, instead of regular declarations. If data on the origin of raw materials is already available in national databases (e.g., Member State systems), operators will not need to re-enter it. This solution will cover virtually all farmers and foresters in the EU.
3. New implementation dates
The Commission also proposed to adjust the deadlines for the EUDR:
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large and medium-sized enterprises: still from December 30, 2025, but with a 6-month transition period for inspection and enforcement;
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micro and small enterprises: the new term is December 30, 2026 (previously planned for June 30, 2026).
This change will avoid system overload and allow more time for testing, training and full implementation of the IT infrastructure.
Maintaining climate ambitions
The Commission emphasises that simplifications do not mean giving up the EUDR's climate ambitionsThe regulation remains a cornerstone of the European Green Deal and the biodiversity strategy. The goal remains to ensure that commodities such as soy, coffee, cocoa, timber, rubber, and palm oil entering the EU market are deforestation-free.
At the same time, the EC announces the continuation of supporting activities:
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launching a "helpdesk" for SMEs,
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further publications of guidelines and FAQs (fourth update in April 2025),
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development of benchmarking of low- and high-risk countries.
Business implications
The Commission's proposal is a long-awaited course correction. Companies will be given more time to implement IT systems, refine supplier relationships, and integrate geolocation data into their due diligence processes.
At the same time, the "first mover" in the supply chain – the importer or manufacturer in the EU – will benefit greater burden of legal responsibility, because its DDS statement will become the basis for the entire chain.
It's worth emphasizing that despite the planned postponement, companies shouldn't delay their preparations. Integrating due diligence processes, verifying the supply chain, and building an internal reporting system (RMS EUDR) remain crucial for maintaining compliance in 2026.
Political context
The Commission clearly maintains a balance between climate ambition and economic pragmatism. The proposal is part of a broader package of legislative measures aimed at simplifying ESG reporting and combating overregulation. According to EC estimates, the proposed changes could reduce administrative costs by up to 30%.
The draft will now go to the European Parliament and the Council of the EU, which must formally approve the change by the end of 2025. If this is not achieved, the EUDR will enter into force on the current date (30 December 2025), which is why the Commission is preparing a contingency plan.
Summary
The Commission's proposal signals that the implementation of the EUDR will be based on robustness and data interoperability, rather than on rushed legislation. While these simplifications are welcomed by the industry, they also shift more responsibility to the first operators – importers and manufacturers who place goods on the EU market.
For companies this means one thing: 2025 will be a key year for building systemic, digital and evidence readinessThose who integrate due diligence processes with analytical tools (such as Reporting Assistant) today will have an advantage when the regulations fully take effect.
