Amendments to the Deforestation Regulation (EUDR) – postponement and simplification

Only operators—those who carry out the first placing on the market or who export the relevant products—are required to conduct due diligence and submit a due diligence statement.

A new category of downstream operator is introduced. It covers any person who places on the market or exports relevant products made using relevant products, all of which are already covered by a due diligence statement or by a simplified statement. The obligations of downstream operators are aligned with those of traders, in that they are no longer required to conduct due diligence or submit due diligence statements. They may place or make available on the market or export the products if they hold certain information, listed in the Regulation, regarding the upstream operator or trader and the downstream actor in their supply chain.

Downstream operators and traders must continue to collect and retain identifying details of suppliers and customers and—where their supplier is an operator—the reference numbers of due diligence statements or the identifiers of statements relating to the products concerned. Notably, only the downstream operator or the trader whose supplier is an operator must collect and retain the reference number of the initial due diligence statement or the identifier of the simplified statement.

Regulation 2025/2650 also introduces the subcategory of micro or small primary operators, covering natural persons or micro or small undertakings established in a country classified as low risk, that place on the market or export relevant products that they themselves have grown, harvested, obtained from, or raised on relevant plots or (in the case of bovine animals) at establishments located in that country. This category is exempt from submitting due diligence statements.

Instead, these operators must submit a single simplified statement in the information system before placing products on the market or exporting them, unless all the required information is available in an existing system or database. They are then assigned a “declaration identifier,” which must accompany their products and without which they may not place the products on the market or export them.

Micro or small primary operators may also substitute precise geolocation with a postal address for all plots of land or the establishment from which the relevant commodities contained in, or used in the manufacture of, the relevant product were produced.

The Regulation’s application dates are amended, and it will now apply from 30 December 2026, except for operators that are natural persons or micro/small enterprises, for whom the application date will be from 30 June 2027.

This extension allows the technical development of the electronic interface to be aligned with the EUDR’s requirements and gives authorities and businesses more time to adapt internal processes, supply‑chain traceability systems, and IT infrastructure, helping them prepare for effective implementation.

The Regulation now excludes from the list of covered products set out in Annex I the category of books, newspapers, prints and other products of the printing industry, manuscripts or typescripts, and plans and drawings, of paper.