EU Deforestation Regulation set for delays

The EU will decide within weeks whether to significantly simplify its EU Deforestation Regulation (EUDR) and postpone its implementation by a year.

The proposed changes include limiting which businesses must comply with EUDR's due diligence requirements, and by when. The rules are currently due to take effect from 30 December 2025 for in scope large and medium-sized companies.

EUDR is the EU's new regulatory regime which is intended to reduce Europe's impact on global deforestation by placing far-reaching obligations, tied to tough enforcement penalties, on businesses that source or sell certain commodities (namely cattle, cocoa, coffee, oil palm, rubber, soya and wood) and many products derived from those commodities.

See our previous article, 'Are you ready for the EU's new Deforestation Regulation?', for a more detailed introduction to EUDR, or read on to learn about the updated position.

Potential postponement

The European Council, on 19 November 2025, proposed delaying the implementation of EUDR by one year, to 30 December 2026 for medium and large-sized operators.

It is also proposed that micro and small-sized operators be given an extra six months, to 30 June 2027.

The Council's proposals notably go further than those previously put forward by the European Commission. The Commission had instead argued for a six-month grace period without enforcement for medium and large-sized operators (but no postponement), and a six-month delay for micro and small-sized operators.

Simplification of duties under EUDR

In further response to concerns over the administrative burden that EUDR would place on businesses, the European Council has also developed the Commission's proposals in relation to the due diligence obligations on different businesses throughout the supply chain.

It is now proposed that the obligation and responsibility for submitting a due diligence statement falls only on the operator that first places the product on the EU market. Downstream businesses would not, it is proposed, need to submit their own due diligence statements, with only the first operator down the supply chain needing to reference the initial statement.

Under the proposals, micro and small-sized operators would be able to submit a one-off simplified declaration.

What happens next?

The proposals now go to the European Parliament. If agreement cannot be reached, the current EUDR rules will be enforceable from 30 December 2025.

Separately, the European Commission has been tasked with carrying out a further simplification review of EUDR by 30 April 2026. The purpose of this review is to assess EUDR's impact and the burden it places on businesses, with a view to proposing more changes if necessary.

Other EUDR developments

While the EU debates when to start enforcing this flagship green regime, a growing body of secondary legislation and official guidance has been published to assist with understanding EUDR's detail.

Country risk ratings

Countries have now been classified as high, standard or low risk in relation to the impact of deforestation and the production of the relevant commodities. Only Belarus, North Korea, Myanmar and Russia have been classed "high risk", while 140 countries have been labelled "low risk". All countries un-named by the regulation are deemed "standard risk".

The purpose of country classifications is to impact the level of due diligence required when sourcing from that country. Low-risk countries benefit from simplified requirements.

Scope of products under EUDR

The scope of products subject to EUDR is being further refined to exclude, for example, second-hand goods.

If you would like to learn more about how your business can comply with EUDR, please get in touch with Ashley Borthwick or Andrew Westbrook, who would be happy to assist you.