On October 21, 2025, the European Commission released a proposal to modify the EU Deforestation Regulation (EUDR). The initiative aims to streamline implementation and decrease administrative burden without compromising environmental protection. This remains a proposal requiring approval from Parliament and the Council before becoming law.
What Would Change if Approved
New Roles and Simplified Obligations
Two new operator categories would be introduced:
- Micro and Small Primary Operators: Small producers with fewer than 10 employees / €2M turnover (micro) or fewer than 50 employees / €10M turnover (small)
- Downstream Operators: Manufacturers or retailers using products already covered by due diligence statements
Key changes under the proposal:
- Operators still conduct full due diligence and file Due Diligence Statements (DDS) in TRACES
- Downstream operators no longer submit DDSs , they register, store, and forward DDS references
- Micro/small operators in low-risk countries may submit simplified declarations instead of full DDS
- All remain accountable for non-compliant material
New Dates and Phased Implementation
- December 30, 2025: Main EUDR start date (unchanged)
- June 30, 2026: Authorities begin conducting compliance checks
- December 30, 2026: Micro and small operators' compliance deadline
Enforcement and Penalties
Risk-based inspection targets under the proposal:
- 9% of operators/products from high-risk sources
- 3% from standard-risk sources
- 1% from low-risk sources
Penalties remain substantial: up to 4% of EU-wide turnover, product confiscation, profit seizures, and possible public procurement / EU funding bans.
What Does Not Change
- Core mission: ensuring deforestation-free, legally produced, traceable products
- Operators must perform comprehensive risk assessments and mitigation measures
- Traceability requirements remain essential throughout supply chains
- Companies exempted from filing DDSs must still monitor suppliers and report identified risks
Business Implications
For Operators
Full due diligence responsibilities continue , supplier assessment, geolocation verification, deforestation risk analysis, and documented mitigation measures remain mandatory.
For Downstream Operators
Focus shifts toward traceability , documenting and forwarding DDS identifiers while reporting concerns to authorities.
For Micro and Small Primary Operators
One-time simplified declarations would be required, with updates only if circumstances change.
The Road Ahead
The proposal enters legislative deliberation with Parliament and the Council. EUDR's fundamental principles , deforestation-free sourcing and traceability , remain unchanged. Enforcement begins within months, emphasising the urgency of preparation regardless of how the proposal develops.