EUDR postponed and simplified: what Regulation (EU) 2025/2650 really changes

The timing of the publication of the amendment and the postponement was, for those with an eye for symbolism, not without irony. On the day before Christmas Eve – traditionally the moment when millions of European households decorate a felled Christmas tree – a regulation was published that postpones and simplifies the application of the EU deforestation framework. In doing so, the postponement was formalised at the symbolic peak of Europe’s largest, socially accepted annual deforestation ritual.

The message for businesses is twofold:

• undertakings are granted more time; and
• for certain actors in the supply chain, administrative obligations are significantly reduced.

The fundamental objective, however, remains unchanged: products associated with deforestation and forest degradation may not be placed on the EU market or exported.

Postponement of the date of application

The EUDR will no longer apply as of 30 December 2025, but instead:

• from 30 December 2026 for medium-sized and large operators and traders;
• from 30 June 2027 for operators that, by 31 December 2024 at the latest, were established as natural persons or as micro or small undertakings within the meaning of Article 3(1) and (2), first subparagraph, of Directive 2013/34/EU, irrespective of their legal form.

This postponement is intended to allow undertakings, Member States and third countries to adapt their systems, processes and IT infrastructure. At the same time, this period is to be used to make the central European information system more robust.

The postponement does not, however, entail any substantive weakening of the EUDR’s objectives. The obligations are deferred, but not abandoned.

Limitation of product scope: certain printed products removed from the scope

A relatively minor but concrete amendment concerns the scope of Annex I to the EUDR. Certain printed products (Chapter 49 of the Combined Nomenclature) have been removed from the scope. This concerns products of the publishing industry, the press or other graphic industries, manuscripts, typescripts and plans, of paper, including, inter alia, books, newspapers and other printed paper products.

For all other relevant commodities (cattle, cocoa, coffee, oil palm, rubber, soy and wood) and their derived products, the EUDR continues to apply in full. The deletion of relevant products “ex 49” derived from the relevant commodity wood in Annex I to the EUDR is not separately motivated in the recitals. Nevertheless, it fits within the legislator’s broader simplification objective: to focus supervision and reporting on products with genuine deforestation relevance and to reduce administrative burdens where the deforestation risk is limited.

New supply chain structure: downstream operators

From “everyone and everything” to a tiered supply chain

The original EUDR was criticised for creating the impression that every company in the supply chain would need to carry out full due diligence anew. Regulation 2025/2650 corrects this by explicitly distinguishing between:

• (primary) operators (first placement on the EU market);
• downstream operators;
• and traders.

The most significant novelty is the category of downstream operators: parties who, in the course of a commercial activity, places on the market or exports relevant products made using relevant products, all of which are covered by a due diligence statement or by a simplified declaration.

Only one “first downstream” with full traceability obligations

A key simplification is that only the first downstream operator (or first downstream trader) is required to:

• collect and retain the reference numbers of due diligence statements, or
• collect and retain the declaration identification numbers of simplified declarations.

Downstream actors further along the supply chain are exempt from this obligation. They do not have to collect reference numbers and do not have to submit a due diligence statement. This prevents a cumulative build-up of administrative burdens.

Non-SME downstream operators and non-SME traders are, however, required to register in the central EUDR information system.

Obligations of downstream operators and traders

Although downstream operators are not required to conduct due diligence, they are not “exempt” from obligations. They must:

• collect information on their suppliers and customers;
• retain reference numbers or declaration IDs (only where their supplier is an operator);
• keep this information for five years;
• inform the competent authorities where there are indications of potential non-compliance.

Substantiated concerns

The amended EUDR distinguishes between:

• substantiated concerns (claims concerning non-compliance, supported by sufficient reasons and based on objective and verifiable information); and
• other relevant information.

Where substantiated concerns exist, stricter obligations apply to non-SME downstream operators and traders: they must verify that due diligence has been carried out and may only place the product on the market if the risk is found to be negligible. In other cases, it is sufficient to inform the competent authorities.

Simplified regime for micro and small primary operators

An important amendment concerns the introduction of the category of primary micro or small operators, defined in the newly inserted Article 2(15a) of the EUDR.

For this group, a strongly simplified regime applies:

• no full due diligence statement per product;
• only a one-off simplified declaration in the information system;
• allocation of a declaration identification number;
• the possibility to replace geolocation data with a postal address;
• an exemption where equivalent data are already available in existing systems.

Monitoring, controls and penalties: the core remains intact

The enforcement architecture remains robust. Member States must carry out annual checks based on risk profiles (3% standard risk, 9% high risk, 1% low risk). Penalties may amount to at least 4% of the total annual EU turnover.

Simplification review in 2026

The Commission must carry out a simplification review by 30 April 2026 at the latest. This means that, even after this amendment, the EUDR is not yet set in stone.

Practical point of attention: the transitional period 2026–2027

An open question remains how downstream operators should deal with the period from 30 December 2026 to 30 June 2027, during which the EUDR already applies to downstream actors but not yet to micro and small primary operators. Further clarification appears warranted.

Conclusion

Regulation (EU) 2025/2650 brings relief, but not leniency. The core principle remains: deforestation-free products are a strict market access requirement. The additional year must be used to design compliance systems that are both robust and flexible, taking into account the possibility of further amendments after April 2026.

Those who treat this period merely as a postponement and delay further preparation risk seeing the announced simplification turn, in the short term, into a complex and time-critical implementation challenge.

About Ploum’s Customs, Trade & Logistics practice group

Ploum’s Customs, Trade & Logistics practice group advises and litigates on all aspects of international trade and logistics. The team has in-depth expertise in EU customs law, international trade law, product regulation and logistics matters, and assists companies both with strategic compliance issues and in administrative and civil proceedings against supervisory authorities and other parties in trade and logistics chains.

For questions regarding the EUDR and its implications for your organisation, please contact Jikke Biermasz, Marijn van Tuijl and/or Michael Hajdasinski. They are happy to advise on the legal and practical impact of the EUDR on your business and throughout your supply chain.