Regulation (EU) 2023/1115 on products associated with deforestation and forest degradation (“EUDR”) has entered a new phase of simplification following the adoption of Regulation (EU) 2025/2650 of 17 December 2025. This amendment notably postponed the application of the Regulation’s main obligations by one year and introduced several substantive adjustments aimed at reducing the administrative burden on operators and traders. The Commission therefore recalls that the December 2025 reform grants an additional year before the effective application of the framework, now scheduled, in principle, to apply from 30 December 2026 for large and medium-sized companies, and from 30 June 2027 for micro and small enterprises.
In this context, the European Commission published, on 4 May 2026, a new simplification package comprising a report to the European Parliament and the Council, an updated version of the FAQ, a revised guidance document, and a draft delegated act amending Annex I to Regulation (EU) 2023/1115, which determines the products and customs codes falling within the material scope of the EUDR. This package aims to clarify the applicable obligations, secure the use of the Information System, specify the role of downstream operators and traders, and adjust the material scope of the Regulation by adding or removing certain products listed in Annex I.
The Commission’s report concludes that the simplification measures adopted in 2024 and 2025, combined with the new measures presented in May 2026, result in a substantial reduction of the administrative burden, in particular for operators sourcing from low-risk countries, micro and small primary operators, and actors located downstream in the supply chain. The Commission consequently states that it does not consider it appropriate to propose a further amendment to the basic Regulation, in order to preserve legal certainty and the predictability of the applicable framework.
The draft delegated act published for consultation notably provides for horizontal exclusions for certain samples, products intended for examination, analysis or testing, used or second-hand products, as well as clarifications concerning packaging, waste and composite products. It also proposes to remove certain products from the scope of the EUDR, notably retreaded tyres and bovine hides and leather, while adding certain derived products in order to avoid breaks in the chain of obligations, such as soluble coffee, certain palm oil derivatives, including soap made with palm oil, and frozen bovine tongues.
Against this background, companies must continue preparing for compliance with the EUDR, while taking into account two distinct levels of development: on the one hand, the simplifications now incorporated into the Regulation following the December 2025 amendment; and, on the other hand, the adjustments still under discussion concerning the scope of products covered by Annex I to Regulation (EU) 2023/1115. The table below presents the main changes introduced by the December 2025 reform and the resulting simplification measures.
| BEFORE (Commission proposal) | AFTER (Parliamentary amendments) | DETAILED EXPLANATION OF THE CHANGE |
| Recital 6: full traceability for all downstream operators. | Obligation limited to the first downstream operator. | Parliament has scaled back the requirement for continuous traceability. The Commission wanted due diligence records to follow the product throughout the supply chain. Parliament has focused the obligation on the first operator following the initial operator. Operators further down the chain would therefore no longer be required to systematically collect and retain these records. |
| Recital 7: category of ‘micro and small primary operators’. | Products must be produced in the relevant low-risk country. | The Parliament adds a territorial condition. A micro or small primary operator would only be eligible for the simplified regime if the products have been grown, harvested, obtained or reared in the same country classified as low-risk. This prevents an operator established in a low-risk country from using the simplified regime for products originating from another country. |
| Recital 8a omitted. | Option to replace geolocation with a postal address. | Significant new simplification: micro and small primary operators could provide a postal address instead of precise GPS coordinates, provided that this address clearly identifies the location of the plots or the establishment. This reduces the technical burden associated with collecting geospatial data. |
| Recital 11: legal form irrelevant for classifying an SME. | Extension to operators exceeding certain thresholds if their EUDR activities remain below the thresholds. | The Parliament introduces a functional approach: an operator that exceeds the overall SME thresholds could still be treated as a micro or small primary operator if the part of its activity covered by the EUDR remains limited. This significantly broadens the scope of the simplifications for mixed or diversified structures. |
| Recital 12a omitted. | Commission simplification report by 30 April 2026. | The Parliament requires the Commission to carry out a rapid review of the Regulation, even before the general review scheduled for 2030. This report should assess the administrative burden, particularly for micro and small operators, and could lead to guidelines, IT improvements, delegated acts or a new legislative proposal. |
| Recital 12b omitted. | General 12-month postponement. | The Parliament proposes to postpone the application of the main obligations by one year. This postponement aims to give Member States, third countries, operators and traders more time to prepare their due diligence systems and resolve practical compliance difficulties. |
| Recital 13: specific deadline for micro and small enterprises until 30 December 2026. | Deleted. | This provision becomes redundant under the Parliament’s approach, as the Parliament is introducing a general deferral. The timetable is therefore reorganised: instead of a deferral limited to certain categories, the deferral becomes broader and more comprehensive. |
| Recital 15: possible warnings prior to enforcement. | Deleted. | The Commission had envisaged a transitional phase during which the authorities could issue warnings accompanied by recommendations. Parliament has removed this mechanism. This may be explained by the desire to postpone implementation rather than maintain a flexible implementation period with warnings. |
| Recital 16: adjustments relating to the timetable for micro/small operators. | Adjustments linked to the general 12-month postponement. | Parliament replaces a targeted postponement approach with a general postponement approach. All related dates must therefore be realigned: repeal of the Timber Regulation, transitional provisions, electronic customs interface and the timetable applicable to operators. |
| Article 2, point 15a: strict definition of a micro or small primary operator. | Definition extended to certain operators exceeding the SME thresholds. | The Parliament amends the definition directly. This would include not only natural persons, micro and small enterprises, but also certain operators exceeding the thresholds if the balance sheet items, turnover and workforce figures relating to the activities covered by the EUDR remain below the thresholds. This is a substantial extension of the simplified regime. |
| Article 4a(1): exemption from the obligations of Article 4(2), (3) and (4)(c). | Exemption reworded and more targeted. | The Parliament specifies that the exemption applies to Article 4(2), the second sentence of Article 4(3) and Article 4(4)(c). This clarification avoids an overly broad exemption of the whole of paragraph 3. It clarifies the obligations that remain applicable to micro and small primary operators. |
| Article 4a(2): simplified declaration. | ‘Single simplified declaration’. | Parliament emphasises the single nature of the declaration. The idea is that a micro or small primary operator would not have to submit a declaration for each operation, but a single simplified declaration prior to placing on the market or export. |
| Article 4a(3): updating of information following any changes. | Updates only in the event of a major change. | The Commission required an update whenever information changed. Parliament limits this obligation to major changes. This reduces the risk of non-compliance for minor changes and avoids a continuous administrative burden. |
| Article 4a(4): exemption if all information exists in another database. | Retained, with simplified ‘single declaration’ terminology. | The principle remains the same: if the data is already available in an existing Union or Member State system, the operator does not have to resubmit it. The Parliament simply harmonises the wording with the concept of the simplified single declaration. |
| Article 4a(5): postal address of parcels permitted. | Postal address of parcels or the holding. | The Parliament is expanding the alternative to geolocation. The postal address no longer applies only to parcels, but also to the holding, which is particularly relevant for cattle or certain supply chains where identifying the holding is more practical than identifying each parcel. |
| Article 5(1): obligation regarding placing on the market. | Addition of placing on the market and export. | The Parliament clarifies that downstream operators and traders may not place on the market, make available or export products if they do not have the required information. This broadens the scope of the obligation and avoids ambiguity regarding exports. |
| Article 5(3)(a): information and references required in all cases. | References required only if the supplier is an operator. | The Parliament limits the obligation to collect due diligence references or declaration identifiers to cases where the supplier is an operator. Where the supplier is not an operator, the obligation does not apply in the same way. This reduces the administrative burden on downstream actors. |
| Article 5(5): transmission of references to subsequent actors. | Deleted. | Major change: downstream operators and traders should no longer be required to pass on due diligence references to the operators or traders to whom they supply products. This breaks the automatic flow of references within the supply chain. |
| Article 26(4): references available to customs prior to import/export. | Exclusion for exports by a downstream operator. | Parliament retains the obligation to make references available to customs, but excludes the case of export by a downstream operator. This reduces customs obligations for actors who are not responsible for the initial placing on the market. |
| Article 34(1a) omitted. | Review of the Regulation by 30 April 2026. | The Parliament adds a fast-track simplification clause. The Commission should examine the practical difficulties of the Regulation and submit a report, accompanied where appropriate by a legislative proposal. This is a political review clause with a very short timeframe. |
| Article 34(2a) absent. | Permanent stakeholder group. | Parliament wishes to establish a permanent channel for dialogue between the Commission, experts, operators and stakeholders. The aim is to identify best practices and technical difficulties following the entry into force of the Regulation. |
| Article 37(1): repeal of the Timber Regulation on 30 December 2025. | Postponed to 30 December 2026. | The Timber Regulation No 995/2010 would remain applicable for a further year. This avoids a gap or an overly abrupt transition between the old timber regime and the new deforestation regulation. |
| Article 37(2): detailed transitional regime until 2026/2028. | Deleted. | The Parliament has removed the transitional regime proposed by the Commission and replaced it with a different, simpler and extended mechanism. This aims to make the transition clearer, particularly for timber products already produced before the EUDR came into force. |
| Article 37(2a) omitted. | Application of the Timber Regulation until 31 December 2029 for certain timber products. | Parliament significantly extends the transition period for timber and timber products produced before 29 June 2023 and placed on the market from 30 December 2026. These products would remain covered by the old Timber Regulation until the end of 2029. |
| Article 37(3): EUDR compliance from 31 December 2028. | Postponed to 31 December 2029. | The timber products concerned would only have to comply with Article 3 of the EUDR from 31 December 2029. This postpones the full transition to the new regime by one year. |
| Article 38(2): main application from 30 December 2025. | Main application from 30 December 2026. | This is the crux of the postponement: the substantive obligations, in particular the prohibition on placing non-compliant products on the market, due diligence, checks and corrective measures, would be postponed by one year. |
| Article 38(2a) omitted. | Reporting of IT difficulties to the Commission. | Competent authorities should notify the Commission of any difficulties, errors or disruptions relating to the Union’s information systems. This acknowledges that IT problems may prevent operators from complying properly. |
| Article 38(3): micro/small enterprises by 30 December 2026. | Application from 30 June 2027 for natural persons, micro and small enterprises. | Parliament grants the smallest operators an additional six months compared to the general deferral. Their deadline is therefore 30 June 2027, except for certain products covered by the Timber Regulation. |
| Article 38(4): specific regime for micro/small primary operators. | Deleted. | Parliament has deleted this standalone paragraph, probably because the regime has been reintegrated into the new framework of deadlines. This avoids an overlap of dates and categories. |
| Article 38(5): phased schedule of checks + warnings. | Deleted. | Parliament has removed the provision for the phased implementation of the articles relating to inspections, corrective measures and penalties. The timetable has been simplified to align with the new general deadlines. |
| Article 38(5a) omitted. | Account taken of IT bugs to avoid sanctions. | The authorities must take into account the Commission’s communications regarding IT problems or unintentional errors in order to avoid unjustified administrative sanctions. This provides explicit protection for operators facing system failures. |
| Annex I: ex 49 products included. | Removal of ex 49 products. | Products falling under category ex 49 would be removed from the scope of the Regulation. This reduces the material scope of the EUDR for certain printed/paper products concerned. |
| Annex III: ‘simplified declaration’. | ‘Single simplified declaration’. | Terminological amendment consistent with Article 4a. It confirms that the scheme for micro and small primary operators is based on a single declaration, rather than a declaration repeated for each operation. |
| Annex III, point 2: quantities to be declared. | Estimated and single annual quantity. | Micro and small primary operators could declare an estimated annual quantity instead of exact data for each individual operation. This significantly reduces the requirement for precision, particularly for small producers whose volumes may vary. |
| Annex III, point 3: country + address or geolocation of the parcels. | Addition of the establishment’s address. | The declaration could include the establishment’s postal address, in addition to the parcels. This better adapts the system to products derived from cattle or to supply chains where the establishment is the relevant unit of identification. |