On 23 December 2025, Regulation (EU) 2025/2650, which amends Regulation (EU) 2023/1115 (the EU Deforestation Regulation, EUDR1)), was published. This amendment introduces an extension of the EUDR application date, together with certain measures aimed at simplifying procedural requirements. This article examines the key changes and their implications.
1) EUDR (EU Deforestation Regulation): A regulation that entered into force on 29 June 2023 with the objective of preventing deforestation and forest degradation, by regulating the placing on the EU market and the export of certain commodities and relevant products. For further details, please refer to the news article “Understanding the EU Deforestation Regulation (EUDR)”.
Background to the Amendment
The EUDR was established to protect forests. However, in practice, concerns have been raised regarding the complexity of its procedures, the resulting negative impact on business competitiveness, and the operational burden associated with due diligence information systems. Accordingly, while maintaining the original objective of forest protection, this amendment seeks to reduce unnecessary administrative burdens and procedural requirements faced by companies.
Key Changes
1. Postponement of the Application Date by One Year
In order to ensure a smooth transition to the new regulatory framework and to allow sufficient time for improvements to the EUDR information system, the dates on which EUDR obligations become applicable have been postponed as outlined below.
Scope | Previous | Current |
|---|
Large operators | 30 December 2025
| 30 December 2026
|
Micro and small operators1) | 30 June 2026
| 30 June 2027
|
1) Micro and small operators: Refer to the definitions from Article 3(1) & 3(2) of 2013/34/EU
2. Introduction of New Concepts & Differentiation of Obligations
In order to prevent duplication of due diligence, ensure continuity of due diligence through the EUDR information system, and reduce administrative burdens on companies, the amendment introduces two new concepts—first downstream operator1) and downstream operator2)—and differentiates obligations according to the stage of the supply chain.
1) First downstream operator: An operator that first places on the EU market or exports from the Union a product for which due diligence in accordance with the EUDR has been performed.
2) Downstream operator: An operator operating at a stage of the supply chain subsequent to the first downstream operator.
- Only the first downstream operator is required to collect and retain the due diligence statement reference number or declaration identifier and to register this information in the EUDR information system.
- Subsequent downstream operators are exempt from the above-mentioned obligations.
- However, non-SME3) downstream operators remain subject to the obligation to register in the EUDR information system.
3) Non-SMEs (micro, small and medium-sized enterprises): As defined in Article 3(1), (2), and (3) of 2013/34/EU.
3. Simplified Regime for Micro or Small Primary Operators
A definition of “micro or small primary operators4) has been added. In addition, for these operators, the amendment introduces exemptions from certain obligations and relaxed requirements in order to minimize administrative burdens.
4) Micro or small primary operators: Natural person or micro/small undertaking established in low-risk countries that place on the EU market or export from the EU products made from commodities they have directly produced.
Instead of submitting a due diligence statement each time a product is placed on the market, such operators are required to submit a one-off simplified declaration, which is assigned a single declaration identifier.
Where the information required for the simplified declaration is already available in the EUDR information system and is linked by the competent authorities of the Member States, micro and small primary operators are exempt from the obligation to submit a separate simplified declaration.
In addition, a postal address of the production site may be used in place of precise geolocation data.
Impact on Businesses Following the Amendment
This amendment has the potential to reduce administrative burdens for certain supply chain actors. However, the situation may evolve depending on the outcome of the review scheduled for 2026.
During the postponed application period, companies should reassess their position within the supply chain, redefine their applicable obligations, and review their EUDR compliance frameworks accordingly.
Potential Use of IMDS
With IMDS Release 15.1 (October 2025), the EUDR has been newly incorporated into the Regulation Wizard. As a result, companies can use IMDS to collect and manage EUDR-related information and to demonstrate regulatory compliance by ensuring data consistency across the supply chain. IMDS is not intended to replace the official EUDR information system, but rather to serve as a complementary tool.
In particular, for companies—such as those in the automotive industry—where IMDS-based data management is already well established, leveraging existing systems is expected to provide practical support in defining the scope of EUDR compliance and clarifying responsibility structures.
[Fig. 1: EUDR-relevant substances require regulatory information input]
[Fig. 2: The information can be entered thru the dialog of regulation wizard]
On 23 December 2025, Regulation (EU) 2025/2650, which amends Regulation (EU) 2023/1115 (the EU Deforestation Regulation, EUDR1)), was published. This amendment introduces an extension of the EUDR application date, together with certain measures aimed at simplifying procedural requirements. This article examines the key changes and their implications.
1) EUDR (EU Deforestation Regulation): A regulation that entered into force on 29 June 2023 with the objective of preventing deforestation and forest degradation, by regulating the placing on the EU market and the export of certain commodities and relevant products. For further details, please refer to the news article “Understanding the EU Deforestation Regulation (EUDR)”.
Date of publication: 23 December 2025
Date of entry into force: 26 December 2025
Background to the Amendment
The EUDR was established to protect forests. However, in practice, concerns have been raised regarding the complexity of its procedures, the resulting negative impact on business competitiveness, and the operational burden associated with due diligence information systems. Accordingly, while maintaining the original objective of forest protection, this amendment seeks to reduce unnecessary administrative burdens and procedural requirements faced by companies.
Key Changes
1. Postponement of the Application Date by One Year
In order to ensure a smooth transition to the new regulatory framework and to allow sufficient time for improvements to the EUDR information system, the dates on which EUDR obligations become applicable have been postponed as outlined below.
Large operators
30 December 2025
30 December 2026
Micro and small operators1)
30 June 2026
30 June 2027
1) Micro and small operators: Refer to the definitions from Article 3(1) & 3(2) of 2013/34/EU
2. Introduction of New Concepts & Differentiation of Obligations
In order to prevent duplication of due diligence, ensure continuity of due diligence through the EUDR information system, and reduce administrative burdens on companies, the amendment introduces two new concepts—first downstream operator1) and downstream operator2)—and differentiates obligations according to the stage of the supply chain.
1) First downstream operator: An operator that first places on the EU market or exports from the Union a product for which due diligence in accordance with the EUDR has been performed.
2) Downstream operator: An operator operating at a stage of the supply chain subsequent to the first downstream operator.
3) Non-SMEs (micro, small and medium-sized enterprises): As defined in Article 3(1), (2), and (3) of 2013/34/EU.
3. Simplified Regime for Micro or Small Primary Operators
A definition of “micro or small primary operators4) has been added. In addition, for these operators, the amendment introduces exemptions from certain obligations and relaxed requirements in order to minimize administrative burdens.
4) Micro or small primary operators: Natural person or micro/small undertaking established in low-risk countries that place on the EU market or export from the EU products made from commodities they have directly produced.
Instead of submitting a due diligence statement each time a product is placed on the market, such operators are required to submit a one-off simplified declaration, which is assigned a single declaration identifier.
Where the information required for the simplified declaration is already available in the EUDR information system and is linked by the competent authorities of the Member States, micro and small primary operators are exempt from the obligation to submit a separate simplified declaration.
In addition, a postal address of the production site may be used in place of precise geolocation data.
Impact on Businesses Following the Amendment
This amendment has the potential to reduce administrative burdens for certain supply chain actors. However, the situation may evolve depending on the outcome of the review scheduled for 2026.
During the postponed application period, companies should reassess their position within the supply chain, redefine their applicable obligations, and review their EUDR compliance frameworks accordingly.
Potential Use of IMDS
With IMDS Release 15.1 (October 2025), the EUDR has been newly incorporated into the Regulation Wizard. As a result, companies can use IMDS to collect and manage EUDR-related information and to demonstrate regulatory compliance by ensuring data consistency across the supply chain. IMDS is not intended to replace the official EUDR information system, but rather to serve as a complementary tool.
In particular, for companies—such as those in the automotive industry—where IMDS-based data management is already well established, leveraging existing systems is expected to provide practical support in defining the scope of EUDR compliance and clarifying responsibility structures.
[Fig. 1: EUDR-relevant substances require regulatory information input]
[Fig. 2: The information can be entered thru the dialog of regulation wizard]