EUDR: What Changes, What Doesn’t, and What Companies Should Prepare For

The Council and the European Parliament have reached a provisional political agreement on the targeted revision of the EU Deforestation Regulation. This agreement confirms the direction set earlier by the Commission and the co-legislators: a postponement of the obligations, a clearer allocation of responsibilities, and several simplification measures. 

These changes are designed to ensure that companies, traders and authorities can implement the regulation effectively once obligations apply. The core requirements of the EUDR, however, remain unchanged. Companies must therefore adjust their preparation plans while maintaining the ambition required by the regulation.

What Changes: Updated Timelines and a More Focused Submission Model

Under the agreement, all operators will be subject to the EUDR obligations as of 30 December 2026. Micro and small operators will benefit from an additional six-month period, with obligations applying from 30 June 2027. The grace period originally proposed by the Commission has been removed to provide a single, clear application date for all large and medium companies.

The simplification measures refine how due diligence responsibilities are allocated. Only the operator who first places a product on the EU market will submit the due diligence statement. The first downstream operator will collect and retain the reference number associated with this initial submission. Operators further down the chain will no longer be required to pass the number along or manage additional due diligence declarations. For micro and small primary operators, the agreement confirms a single simplified declaration and a unique identifier that will serve as a traceability reference.

The co-legislators also agreed to remove specific printed paper products from the scope of the regulation, acknowledging their limited deforestation risk. This adjustment ensures that obligations focus on commodities and products where due diligence requirements are most relevant.

What Does Not Change: Core Requirements and Documentation Expectations

The agreement does not modify the substantive elements of the EUDR. The product scope for deforestation-linked commodities remains the same. Companies must continue to obtain complete geolocation information for all relevant plots of land and maintain traceability across their supply chains.

Risk assessment criteria, documentation expectations and evidence requirements remain fully applicable. Companies must be able to demonstrate the basis of their due diligence decisions and retain supporting material. The liability framework is unchanged. The simplification measures adjust the process by which due diligence is submitted, but not the underlying obligations or the level of scrutiny expected.

Why These Adjustments Were Made: IT Capacity and Implementation Feasibility

The Commission and co-legislators acknowledge that the volume of expected due diligence submissions is significantly higher than initially projected. The postponement is intended to provide authorities with time to reinforce the EU’s information system and ensure stable performance once obligations apply. The agreement also introduces a requirement for competent authorities to report significant IT system disruptions to the Commission. This measure is designed to support monitoring of system performance while limiting additional administrative burden.

The co-legislators also emphasised continued engagement with experts and stakeholders through existing Commission platforms. This engagement aims to support consistent implementation and address operational challenges as they arise.

Finally, the Commission is tasked with conducting a simplification review and presenting a report by 30 April 2026. This report will assess administrative burdens, particularly for smaller operators, and propose improvements to the information system. Where necessary, the review may be accompanied by additional legislative proposals.

What Companies Should Prepare For: A Structured and Realistic Roadmap

The transition period requires companies to realign their EUDR implementation plans. A first priority is to identify, for each product and flow, which entity qualifies as the “first placer” on the EU market. This designation will determine which organisation is responsible for submitting the due diligence statement and how documentation responsibilities should be structured.

Data consolidation remains essential. Organisations must confirm the completeness and accuracy of supplier information, geolocation data and commodity characteristics. Documentation flows should be updated to reflect the revised allocation of responsibilities across the supply chain. Governance models must clearly define roles for risk assessment, internal controls and documentation retention.

At the same time, companies should assess the readiness of their internal systems. Information must be structured in a way that supports due diligence logic and future interaction with the EU’s information system. Implementation timelines for 2025 - 2027 should be adjusted accordingly, ensuring that the organisation is prepared well ahead of the updated obligations.

A Clearer Framework with the Same Level of Expectation

The updated agreement provides clarity on timelines and responsibilities. It offers companies a defined period to build the governance, data and documentation structures required under the EUDR. The postponement does not reduce the ambition of the regulation. Once the information system is reinforced and authorities fully operational, companies should expect a more structured and more rigorous review of due diligence information.

This means preparation cannot be deferred. Organisations must use this transition window to ensure that their supply chain data, documentation logic and internal controls can withstand closer scrutiny once obligations apply.

At DOJÖ, we support organisations in assessing their current position, identifying structural gaps and designing EUDR programmes that are operational, defensible and scalable. For companies seeking clarity on how these changes affect their implementation path, our team can help structure the approach and provide the oversight required for a compliant transition.