New EUDR Amendment (COM(2025)652): What It Means for State Forests

On 21 October 2025, the European Commission published COM(2025)652, a proposal to amend the EU Deforestation Regulation (EUDR, Regulation 2023/1115). The amendment claims to simplify compliance obligations for operators and traders, without changing the Regulation’s core environmental objectives.

Key Elements of the Proposal

1. New category – “micro and small primary operators”
The proposal introduces a new category designed to reduce the administrative burden on the smallest market participants. Under this new approach: Micro and small operators located in low-risk countries will no longer need to submit a full due diligence statement. Instead, they will file a one time simplified declaration, listing:Operator identity and address; Harmonised System (HS) code and description of the wood products; Annual production quantity; Postal address or geolocation of forest plots.  Once submitted, the operator receives a declaration identifier, which must accompany the wood products throughout the supply chain. In practice, this means that small-scale producers are now effectively exempted from the full due diligence requirements that apply to larger operators. Their compliance obligation will be limited to filing this one-time declaration.

2. Larger and downstream operators

Large and non-SME operators will continue to carry out full due diligence and risk assessments. Downstream operators using wood already covered by a due diligence statement will not need to submit new ones but must pass along the relevant identifiers (reference numbers)  to ensure traceability.

3. Risk-based enforcement

Competent authorities will maintain a risk-based approach, focusing inspections on high-risk origins and operators with previous compliance issues.

Implementation Timeline

General application of the EUDR: 30 December 2025

Micro and small operators: 30 December 2026

Enforcement by competent authorities: 30 June 2026, or 30 December 2026 for small operators

Impact on State Forests

For state forest operators, these amendments will likely have little direct impact. Public forest enterprises and national forest agencies are not “micro or small” operators under EU size definitions, and most have already worked extensively over recent months to prepare for EUDR implementation.

State forests typically operate under strict legal frameworks, transparent management systems, and independent auditing. They are already subject to strong national and EU scrutiny on legality, sustainability, and traceability.
As a result, the EU DR provisions mainly represent an additional reporting obligation. The main beneficiaries of the new simplification proposal are the small-scale private operators that are now largely exempted from due diligence obligations.

EUSTAFOR will carefully follow and analyse these developments, including their implications for state forests, market dynamics, and the broader implementation of the EUDR.

The European Commission will present and discuss this proposal during the Deforestation Platform meeting on Friday, 24 October.