EUDR Amendment: Parliament and Council Align on Delay and Simplifications

The European Parliament and the Council have both endorsed their positions on the amendment to the EU Deforestation Regulation (EUDR). Both institutions support a one-year postponement of the Regulation’s application and a substantial simplification of due-diligence requirements, particularly for downstream, micro, and small operators.

EU Ambassadors in COREPER I were the first to formalise their stance on the EUDR amendment, endorsing the Council’s negotiating position on 19 November 2025. Their approach centres on delaying the Regulation’s application for all operators and significantly simplifying due-diligence obligations. The aim is to reduce administrative pressure, address IT-system delays, and give businesses and authorities a more practical timeline for implementation.

Under the Council’s mandate, the start date of the EUDR would be postponed to December 2026 for medium and large operators and June 2027 for micro and small operators. The Council also proposed a structural simplification: only the first operator placing a product on the EU market would submit a due-diligence statement, while downstream operators would merely pass on the reference number. Micro and small primary operators would face minimal administrative requirements, submitting only one simplified declaration. In addition, the Council requires the Commission to carry out a simplification review by April 2026, with the option to propose further amendments.

When the European Parliament adopted its position today, on 26 November, it broadly echoed the Council’s priorities. Parliament confirmed the same delayed application dates, supported lighter obligations for small operators, and endorsed the principle of reducing downstream burdens. While Parliament added some refinements—such as clarifying the definition of micro and small primary operators and adding flexibility for authorities during early enforcement—the overall direction closely mirrors the Council’s approach. Parliament also backed a permanent stakeholder group to help operators adapt and to provide technical input throughout the Regulation’s rollout.

Key Provisions Reflected in Both Positions

• One-year postponement of application:
• Medium/large operators: 30 December 2026
• Micro/small operators: 30 June 2027
• Strong simplification of due-diligence duties, with responsibility centred on the first operator placing products on the market and reduced obligations for downstream actors.
• One-off simplified declaration for micro and small primary operators.
• Review by the Commission by April 2026 to identify further simplification opportunities.

With both institutions broadly aligned, the file now moves into trilogue negotiations. The objective is to finalise the amendment before the current EUDR applicability date of 30 December 2025, enabling the postponement and simplification package to take effect without disruption.

This marks a significant step in the institutional process as trilogues approach. What remains deeply problematic, however, is the level of legal uncertainty that has characterized this process from the start. This experience reflects a broader concern regarding EU legislation: practical feedback is frequently raised early in the process but insufficiently integrated, while regulatory frameworks continue to evolve in ways that are difficult to anticipate. 

For EUSTAFOR members, who already operate under robust national legislation and are subject to extensive sustainability audits, this legislative process highlights persistent challenges. Even with well-established systems in place, new EU DR requirements have necessitated substantial adjustments to internal procedures, traceability frameworks, and compliance operations. Considerable time, effort, and financial resources have already been committed to meeting obligations that, in many things, replicate existing safeguards.

This inevitably raises the question of whether the extensive adjustments may have been largely in vain, given the continuing policy uncertainty and the possibility of further requirements necessitating additional changes.