Commission Proposal to amend the EU Deforestation Regulation

On 21 October 2025, the European Commission published its Proposal to amend the EU Deforestation Regulation (EUDR). Contrary to what was outlined in the letter issued in September, the text does not propose a postponement of the EUDR application date of 30 December 2025. Instead, it offers some solutions not to overcharge the information system and give operators enough time to comply with the Regulation.

Changes proposed to the EUDR: longer enforcement times and additional exceptions

Specifically, the Commission’s Proposal to amend Regulation (EU) 2023/1115 introduces the following modifications:

Postponement for small enterprises: 30 December 2026

The EUDR application date for micro and small operators will be delayed by six months (from 30 June 2026 to 30 December 2026). The application date for large and medium-sized operators remains 30 December 2025.

Six-month enforcement grace period: 30 June 2026

Large and medium-sized operators will benefit from a six-month grace period during there will be no enforcement actions. Accordingly, competent authorities will begin enforcement measures by 30 June 2026 for operators, downstream operators, and traders, and to 30 December 2026 for micro and small operators.

Exemptions from due diligence obligations reporting for non-SMEs

Large downstream operators are exempted from the duty to ensure that due diligence has been carried out and from the requirement to submit their own due diligence statements, as for SME operators and traders.

One-time simplified declaration

Micro and small primary operators will be required to submit a one-time simplified declaration through the information system. Alternatively, they can provide the relevant information via a system or database established under EU or Member State legislation. The required information includes geolocation data or the postal addresses of all land plots where the relevant commodities are produced.

To understand if the EUDR applies to you, contact COSlaw Team here or at coslaw@obelis.net.

References:

European Commission (2025). Proposal for a Regulation of the European Parliament and the Council amending Regulation (EU) 2023/1115 as regards certain obligations of operators and traders. Retrieved on 24/10/2025.