The European Commission has finally opted to maintain the end of December 2025 as the date on which the regulation to combat imported deforestation (EUDR) will apply to medium-sized and large companies, but at the cost of a number of simplification measures.
The decision was taken at the meeting of the European College of Commissioners on Tuesday 21 October, before being presented to the environment coordinators of the European Parliament’s political groups at the end of the morning, and to journalists at midday.
The EUDR regulation will come into force on 30 December 2026 for micro and small businesses, which will therefore be able to benefit from an additional 12 months. Medium-sized and large companies will have to apply it from 30 December 2025, but will benefit from a six-month “grace period” for checks and gradual compliance.
The overloading of the IT system feared by the European Commission, which used it as the reason for a potential further postponement of one year on 23 September (see EUROPE 13715/5), should be avoided by measures to simplify reporting obligations.
By exempting downstream operators in value chains (retailers, large European manufacturing companies) from due diligence statements, the European Commission aims to reduce the number of interactions with the IT system and the amount of data uploaded to it.
The only submission to the system required for the entire supply chain will be made by upstream operators.
The Commission takes the example of cocoa, for which only the importer who places the beans on the EU market will be obliged to complete a due diligence statement and share it with downstream operators. Some 9,000 SME downstream operators would be affected, according to a European Commission official.
Micro and small businesses, on the other hand, are subject only to a “single, simplified statement” in the IT system. They will have to register in the computer system, but will no longer have to produce a due diligence statement each time they sell one of their products. Micro- and small enterprises will also be able to transfer to a Member State authority or to another operator with which they work (a cooperative, in the case of a farmer) to ask them to register them.
Over 95% of farms and forestry businesses in the EU should benefit from these simplifications, as they are micro or small enterprises, explained a European Commission official.
The co-legislators now find themselves in the same position as a year ago, when there was first talk of postponing the implementation of the regulation. Parliament had opted for an urgent legislative procedure (see EUROPE 13510/10) and the Member States had agreed not to touch the substance of the text, thus opposing amendments tabled by the EPP group in the European Parliament during the inter-institutional negotiations (see EUROPE 13528/8).
But a year later, the political context has changed. Meeting in Luxembourg on Tuesday 21 October, the environment ministers of several EU Member States deemed the changes proposed by the European Commission to be insufficient, and called for a complete postponement of the regulation’s entry into force.
Luxembourg, the Czech Republic, Poland and Latvia voted in favour of an overall postponement. The Czech Republic shared its doubts about the “ability of the European Council and the European Parliament to adopt this proposal by the end of the year”. Poland has asked for “a pause in this document so that it can be re-examined”. Luxembourg called for “an in-depth analysis of the possibilities for simplification”, while Latvia called for “more substantial simplification, including other elements”.
At the beginning of July, eighteen Member States called for a further simplification of the regulation, while hinting at their desire to add a ‘zero’ risk country category to the existing ones (‘low’, ‘standard’ and ‘high’) (see EUROPE 13675/9).
The EPP group in the Parliament has been working in the same direction since the end of 2024 and this year. When informed of the changes proposed by the European Commission, Christine Schneider (EPP, German) reiterated her view that this category should be created, according to a parliamentary source. (Original version in French by Florent Servia)