Delay until December 2026 and other developments in the implementation of the EUDR Regulation

Regulation (EU) 2025/2650, published in December 2025, establishes a further postponement of the application of EU’s anti-deforestation law, known as EUDR, until the end of 2026.

Consequently, large operators will need to comply with their main obligations under Regulation (EU) 2023/1115 from 30 December 2026 (30 June 2027 in the case of natural persons and micro and small enterprises).

This Regulation also introduces new measures to clarify definitions, adjust due diligence obligations, and amend provisions relating to review and deadlines, while preserving its fundamental environmental goals and reducing disproportionate burdens on small operators.

What are the main changes?

Introduction of two new categories of actors different from the "operator"

Regulation (EU) 2025/2650 updates the definition of operator and creates two new categories that change how obligations are distributed within the supply chain.

The definition of “operator” (Article 2.15) is updated to clarify that it refers to any natural or legal person who places relevant products on the EU market or exports them, excluding “downstream operators”, a new category covered by this Regulation, along with “micro or small primary operators”:

• “Micro or small primary operator" means a natural person or micro or small enterprise, under EU accounting rules, established in a low-risk country which places on the market or exports the regulated products they themselves have grown or obtained.

• "Downstream operator" means a natural or legal person who, in the course of a commercial activity, places on the market or exports regulated products made from regulated materials, all of which are covered by a due diligence declaration or a simplified declaration.

  Processors and exporters will be considered downstream operators depending on their role in the supply chain:
  • Processors if they take relevant products that have already been subject to due diligence and use them to make other relevant products that they then place on the market or export.
  • Exporters when they export products that were manufactured from relevant products already covered by a due diligence statement or simplified declaration.

Changes in operators' obligations

The Regulation provides for the following modifications to the obligations of operators:

• The obligation and responsibility to submit the due diligence statement lies exclusively with the operators who first place the product on the market. They must keep and transmit the reference number of the initial declaration.
• Operators and traders downstream in the supply chain no longer have to submit their own due diligence statements, they must instead collect and retain the reference number of the initial declaration made by the primary operator.
• Micro or small primary operators in low-risk countries must submit a single simplified declaration in the Information System, the content of which is established in the new Annex III.
• Downstream operators and traders "other than SMEs" will not have to file returns but will need to register in the Information System.
• Regardless of size, all operators will collect and retain (for 5 years):
  • data of the operators, downstream operators or traders who have supplied them with the relevant products,
  • details of downstream operators or traders to whom they have supplied the relevant products.

Application

The application of Regulation (EU) 2023/1115 is planned as follows:

Operators who are natural persons and micro-enterprises for the rest of EUDR products

With this new delay, all businesses will have one more year to comply with new EU rules to prevent deforestation.

This additional time is intended to guarantee a smooth transition, to reduce impact and administrative burden on micro and small operators and to allow time to improve the IT systems that all operators will need to use to make electronic due diligence statements.

Now businesses must check what has changed, adapt their systems, and adjust their commercial arrangements in time to meet the requirements of Regulation (EU) 2023/1115.

More information

• EU Commission – DG Environment: Regulation on Deforestation-free Products
• Deforestation law: Parliament adopts changes to postpone and simplify measures
• Regulation (EU) 2023/1115 on Deforestation-free Products
• Regulation (EU) 2025/2650 of the European Parliament and of the Council amending Regulation (EU) 2023/1115
• Regulation (EU) 995/2010 (EUTR Regulation)