The EUDR news in brief
Main Deadline Confirmed: Contrary to rumors circulated on September 23, the European Commission’s proposal of October 21, 2025 confirms the deadline of December 30, 2025 for the application of the Regulation (EU) 2023/1115 EUDR to large and medium-sized enterprises.
There has been no general postponement.
Relief for small producers: A new category of “micro and small primary operators” (e.g., farmers, foresters) from low-risk countries is introduced. For them, the deadline is postponed to December 30, 2026 and the due diligence obligation is replaced by a simplified one-off declaration.
Simplification for the downstream supply chain: downstream operators will no longer have to submit their own due diligence statement if the product is already covered upstream. However, they remain fully responsible for traceability, having to collect and transmit the identification codes of the declarations.
An unexpected change of course on the Deforestation Regulation
Contrary to the news circulated a month ago about a one-year postponement, on October 21, 2025 the European Commission presented a targeted proposal that, while confirming the general framework of the Deforestation Regulation (EUDR), significantly simplifies its implementation. This strategic move aims to balance the environmental ambition of the regulation with the need to ensure operational sustainability for businesses, responding to the concerns that have emerged in recent months.
The Commission’s decision was reached following analyses that highlighted two main critical issues:
- an excessive administrative burden for some categories of operators
- the risk of overloading the central IT system.
What changes in practice?
The Commission’s proposal is based on three fundamental pillars, each with precise practical implications for the different categories of economic operators involved in the supply chain.
Has the deadline of December 30, 2025 been postponed?
No. The most important point is the confirmation of the main deadline. For large and medium-sized enterprises, the obligation to comply with the EUDR regulation remains set for December 30, 2025. Any hypothesis of a general postponement has been officially denied.
However, the proposal introduces a transition period for the application of sanctions. Inspections and the application of corrective measures by the competent authorities will begin from June 30, 2026. In the period between December 30, 2025 and June 30, 2026, the competent authorities will still be able to issue warnings and recommendations to companies to remedy any non-compliance.
Micro and Small Primary Operators
The Commission has introduced a new category to lighten the load on smaller producers. The definition of “micro and small primary operator” includes natural persons or micro/small enterprises located in countries classified as “low risk” that directly produce the raw materials (e.g., foresters who harvest timber).
Two important concessions are foreseen for these operators:
- Extension of the deadline: the application of EUDR obligations is postponed by one year, to December 30, 2026.
- Bureaucratic simplification: the obligation to submit a Due Diligence Statement (DDS) for each transaction is replaced by a “simplified one-off declaration” to be entered into the IT system. This declaration covers all future sales of the operator, who will be required to update it only in case of substantial changes to the information provided (e.g., addition of new land). The declaration generates a unique “declaration identifier” that will accompany the products throughout the supply chain.
What changes for producers and retailers downstream?
To avoid bureaucratic duplication and reduce the burden on the IT system, the proposal concentrates the responsibility for submitting the Due Diligence Statement (DDS) on the first operator who places the product on the EU market (typically the importer).
Consequently, downstream non-SME operators (e.g., large manufacturers that process already-imported raw materials or retail chains) no longer need to submit a new DDS for the products they purchase. Their obligations now focus on traceability and become:
- Remain registered in the EUDR information system.
- Collect and transmit the reference numbers of the DDS submitted upstream or the declaration identifiers of small producers, ensuring the full continuity of the traceability chain.
This shifts the strategic focus for downstream companies from submitting multiple declarations to managing and verifying traceability data from upstream suppliers.
Specific impact: what does it mean for those who import and sell wood products?
To better understand the operational consequences of these changes, the table below compares the obligations before and after the proposal of October 21, 2025.
| Supply Chain Actor | Previous Obligation (Original EUDR Framework) | New Obligation (Post-October 2025 Proposal) |
|---|---|---|
| Timber Importer (Large Company) | Submit a complete DDS for each batch of timber placed on the EU market. Deadline 30/12/2025. | Unchanged. Must submit a complete DDS for each placement on the EU market. Deadline confirmed for 30/12/2025. |
| Small Forester in an EU Country (“low risk”) | Submit a complete DDS for the timber sold. Deadline 30/06/2026 (as SME). | Submit a simplified one-off declaration that generates an identifier. Deadline postponed to 30/12/2026. (Goal: reduce the administrative burden for small low-risk producers) |
| Furniture Manufacturer (non-SME) purchasing timber already on the EU market | Submit its own DDS for the furniture placed on the market. Deadline 30/12/2025. | No longer needs to submit a new DDS. Must collect and transmit the reference number of the importer’s DDS. (Goal: avoid duplication and reduce the IT system load) |
| Retail Chain (non-SME) selling wooden objects | Submit its own DDS for products sold to consumers. Deadline 30/12/2025. | No longer needs to submit a new DDS. Must ensure traceability by collecting and passing on the reference of the upstream DDS. (Goal: avoid duplication and reduce the IT system load) |
The reasons for the change: IT system stability and reduction of bureaucracy
- Overload of the IT system: Commission documents reveal that projections on the number of declarations, especially those from downstream actors, showed a predicted load on the IT system “much higher than expected”. To ensure stability and operability, it was necessary to drastically reduce the number of transactions, concentrating declaration obligations at the first point of entry into the EU market.
- Reduction of administrative burdens: this proposal is part of a wider agenda aimed at reducing bureaucratic burdens for businesses, particularly SMEs, to support European competitiveness.
Key deadlines
- December 30, 2025: Application date of EUDR obligations for large and medium-sized enterprises.
- June 30, 2026: Start of inspections and application of corrective measures by competent authorities for large and medium-sized enterprises.
- December 30, 2026: Application date of EUDR obligations (in simplified form) for micro and small primary operators from low-risk countries.
Frequently Asked Questions (FAQ)
Does this update mean that the EUDR Regulation is less strict?
I manufacture wooden products and import the raw material from a non-EU supplier. What should I do?
- Implement a due-diligence system, including risk assessment and mitigation.
- Submit the Due Diligence Statement (DDS) in the EUDR IT system.
- Traceability and record-keeping: keep a register of DDS for at least five years; obtain and communicate DDS reference numbers (or declaration IDs) to subsequent downstream operators or traders.
