EU Adopts Amended Regulation
7 min reading
Bruno Fardilha
23/12/2025
Adjusted application timelines
Streamlined due diligence requirements
Changes to product scope
Mandatory simplification review in 2026
Preparation still matters
What this means in practice
Next steps
The Council of the European Union has formally adopted a targeted revision of the EUDR, following approval by the European Parliament. The amending Regulation has now been published in the Official Journal of the European Union, providing legal certainty on the revised timelines and requirements.
These amendments aim to simplify implementation, reduce unnecessary administrative burden, and ensure that operators, traders, and authorities are adequately prepared ahead of the regulation's application, while fully preserving the EUDR's objective of preventing deforestation and forest degradation linked to products placed on the EU market.
Adjusted application timelines
Under the adopted revision, the application of the EUDR is postponed to allow additional preparation time:
- The EUDR will enter into application on 30 December 2026 for all operators.
- Micro and small operators benefit from an additional transition period, with application extended until 30 June 2027, except for those already covered by the EU Timber Regulation.
These adjusted timelines respond to concerns raised by Member States and stakeholders regarding operational readiness and the capacity of the EU's IT systems.
Streamlined due diligence requirements
A central element of the revision is the simplification of due diligence obligations across the supply chain.
Key changes include:
- The obligation to submit due diligence statements (DDS) is now limited to the first operator placing relevant products on the EU market.
- Downstream operators and traders are no longer required to submit new DDS for products already placed on the market. Instead, they must retain and pass along the relevant reference information through the supply chain.
- For micro and small primary operators from low-risk countries, regular DDS submissions are replaced by a simplified one-off declaration.
This approach reduces duplication, particularly for intra-EU trade, while maintaining traceability and accountability at the point of market entry.
Changes to product scope
To further reduce administrative burden where deforestation risk is limited, the revision removes certain printed products — such as books, newspapers, and printed images — from the scope of the regulation.
Mandatory simplification review in 2026
The revision also introduces a new obligation for the European Commission to assess the regulation's impact in practice.
By 30 April 2026, the Commission must publish a simplification review, evaluating the administrative burden of the EUDR, with particular attention to smaller operators. Where appropriate, this review may be accompanied by additional legislative proposals.
This creates a formal mechanism to further refine the regulation based on implementation experience.
Preparation still matters: don't pause compliance work
While the revised timeline provides additional preparation time, it is important not to treat this as a reason to pause compliance efforts.
EUDR compliance is typically a multi-step process that takes time to implement properly. For most companies, preparation involves:
- mapping supply chains and relevant products,
- collecting and validating supplier information,
- establishing internal processes and responsibilities,
- aligning documentation flows across teams and partners, and
- ensuring systems and records will be audit-ready once the regulation applies.
Many of these steps require coordination across procurement, operations, suppliers, and customers, and that coordination is difficult to compress into the final months before the deadline.
In practice, the extended timeline is best viewed as a buffer for structured preparation, not as an opportunity to delay.
What this means in practice
With these amendments now formally adopted and published, EUDR compliance increasingly shifts toward operational execution and information continuity.
- Due diligence efforts are concentrated at the market entry point, rather than repeated across the supply chain.
- For downstream operators, especially within the EU, compliance focuses on maintaining traceability, documentation, and reference data, rather than re-running risk assessments for the same products.
- The overall data load on the EU IT system is reduced, supporting a more stable and scalable implementation.
In practice, this places greater emphasis on how transactions are operated, documented, and tracked on an ongoing basis.
Next steps
With the amending Regulation now published in the Official Journal and in force, attention turns to implementation readiness.
Further guidance and practical clarifications are expected as authorities and operators prepare for application in December 2026.
At Timberhub, we continue to closely monitor EUDR developments and their practical implications, and we will share further updates as implementation guidance evolves.
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