Home » EUDR Balancing Act: European Commission Proposes Targeted Reliefs for Smaller Companies Instead of 12 Months Delay

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EUDR Balancing Act: European Commission Proposes Targeted Reliefs for Smaller Companies Instead of 12 Months Delay

This blog was originally posted on 3rd November, 2025. Further regulatory developments may have occurred after publication. To keep up-to-date with the latest compliance news, sign up to our newsletter.

AUTHORED BY HANNAH JANKNECHT, REGULATORY COMPLIANCE SPECIALIST, COMPLIANCE & RISKS

Following discussions in late September 2025 regarding a potential 12‑month delay of the EU Deforestation Regulation (EUDR) for all companies, the European Commission has now proposed a set of more targeted amendments to the regulation.

These changes are intended to alleviate compliance burdens on smaller companies and downstream operators and to address the underlying issue that was cited as a reason for a potential 12‑month delay, namely the risk of overloading the EUDR IT system. Although the Commission sought to simplify certain obligations through the EUDR Guidance finalized in August 2025, traffic in the system is still expected to remain heavy due to the substantial number of per shipment statements, and the high volume of small‑scale imports.

The new proposal aims to tackle both the impact on smaller companies and the persistent IT capacity concerns. The proposal is also likely a response to the criticism that arose following the Commission’s earlier contemplation of another delay. In an open letter, several major manufacturing companies urged the Commission not to postpone the application date but instead to introduce grace periods of up to six months. Many companies also argued that another delay would not resolve the regulation’s core challenges and would undermine the significant investments already made to meet the existing deadline.

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What Are the Changes to the EUDR Timeline?

Instead of repeating last year’s postponement of the EUDR application for all companies, the EU Commission now proposes to postpone the application date only for small and micro enterprises. If enacted, the new application timeline would look as follows:

30 December 2025: EUDR Application for Large and Medium-sized companies (except enforcement provisions);
30 December 2026: EUDR Application for Small and Micro Enterprises.

Medium, small and micro enterprises are identified using the definitions set out in the Non-Financial Reporting Directive 2013/34/EU.

What Are the Key Priorities and Timelines to Watch Out for in 2026?

The term ‘downstream operators and traders’ refers to those operators and traders that commercialize relevant products that have already been placed on the EU market, for example by transforming or reselling them.

Under the current version of the EUDR, non-SME downstream operators and traders are required to submit their own due diligence statement, but they can refer to existing due diligence statements submitted by upstream operators and traders once they ascertain that due diligence has been properly conducted.

The Commission proposal now aims to eliminate the obligation for downstream operators and traders to submit their own due diligence statement altogether. The Commission provided the following example to illustrate this: ‘Cocoa beans would need only one due diligence statement to be submitted by the importer placing them on the EU market, but downstream manufacturers of chocolate products will not be required to submit a new due diligence statement in the IT system.’

Nevertheless, downstream operators and traders will still be required to register in the information system and they will continue collecting and passing on reference numbers and declaration identifiers.

What is the New Subcategory of Small and Micro Primary Operators?

‘Micro and small primary operators’ is a term that is currently not used in the EUDR. The Commission proposal introduces the term to describe companies that:

Meet the size requirements for small or micro companies;
Are established in a country that is classified as low risk in the EUDR benchmarking system; and
Place on the market or export products which they themselves produce (meaning that they grow, harvest, obtain from or raise the relevant commodities in the relevant products themselves).

According to the proposal, the obligation to submit a due diligence statement shall no longer apply to these micro and small primary operators. Instead, they will submit a one-time simplified declaration in the information system to obtain a declaration identifier, which is then passed on with all relevant products they place on the market or export to ensure traceability.

The information to be contained in this one-time simplified declaration is defined in a new Annex III, and it includes:

Operator name and address;
Harmonized System code and free-text description of the relevant products, including the trade name, and the annual quantity of relevant products intended to be placed on the market or exported;
Country of production and the postal address or the geolocation of all plots of land on which the micro and small primary operator produces relevant commodities;
Due diligence declaration covering all future products.

When is the EUDR Going to be Enforced?

While the Commission proposal does not suggest delaying the due diligence obligations for large and medium-sized companies, it proposes a grace period of 6 months regarding the enforcement and application of sanctions. From 30 June 2026, national authorities will begin enforcing the rules set out in Articles 16 to 19, Article 22, and Article 24 for large and medium-sized operators, downstream operators, and traders. For micro and small operators, these enforcement obligations will apply six months later from 30 December 2026. This phased timeline is intended to give businesses time to comply with the new requirements while offering a transition period to adjust to the legislative changes. However, where authorities become aware of a case of non-compliance during this transitional period, they may issue warnings to the economic operator.

As a consequence, the date for the general review of the Regulation, which will also entail a reassessment of a potential expansion of the EUDR’s product scope, has been moved to 30 June 2030 to allow sufficient time to assess the effects of its enforcement.

Next Steps

The proposal will now be discussed by the Council and the European Parliament, with the Commission calling for a swift adoption of the amendment. Given the tight timeline, the European Commission highlighted in the accompanying press release that they are preparing “contingency plans” to ensure economic operators can meet their obligations by 30 December 2025, should the proposal not be adopted in time by the co-legislators. However, neither the press release nor the proposal itself provides details on what these contingency plans might entail.

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