Last month, we wrote about multiple proposed delays for the EU’s Deforestation Regulation (EUDR). Now those delays, along with substantive changes to the EUDR, are taking shape. Both the EU Council and Parliament reached negotiating positions on the EUDR, meaning that trilouges can begin. A recent Linklaters memo discusses the substance of those positions, noting that both include the following amendments:
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“The EUDR would apply from 30 December 2026 for medium and large operators, and from 30 June 2027 for micro and small operators.
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Only operators first placing products on the market would be required to submit due diligence statements .
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Only the first downstream operators would have to keep and pass on the reference number of the initial statement.
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Micro and small primary operators only would submit a one-off simplified declaration, with no obligation to update it.
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The definition of micro and small primary operators would be broadened, looking only at the relevant parts of balance sheet total, net turnover and average number of employees concerning EUDR activities.”
We can expect the trilouge process to move quickly because the current EUDR is set to come into effect at the end of December. To avoid confusion and compliance burdens, the amendments, including the one-year implementation delay, must be passed before December 30, 2025. However, this set of amendments may not be the end of simplification measures for the EUDR. Included in the package is a mandate to the European Commission to conduct a simplification review of the EUDR by April 30, 2026. This review will focus on the expected compliance burdens and recommendations for reducing them, particularly for small and micro companies.
Our members can learn more about the EUDR here.
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