The EU Deforestation Regulation (EUDR) has been updated. Again.

The EUDR (EU Deforestation Regulation) is an EU law designed to ensure that certain products sold in the EU do not come from land linked to deforestation or forest degradation.

On 27 November 2025, the EU Parliament voted to approve a new amendment to the EUDR, with 402 votes in favour, 250 against, and 8 abstentions. The approved amendment contains some further “surprises” with respect to previous versions. Most strikingly, a substantial simplification of due diligence requirements for a large number of EU-based operators and traders, but also some simplifications for upstream operators, in particular small producers of goods that are imported to the EU. 

By the end of 2025: The final shape of the EUDR

The regulation now enters a new negotiation phase with the EU Member States. Before reading further, keep in mind: more updates and amendments are still possible. If no further delays occur, the final version of the law should be approved by the end of 2025. Moreover, this article is for general informational purposes only and must not be interpreted as legal advice.

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Who falls under the scope of the new EUDR proposal?

The EUDR’s official title is Regulation (EU) 2023/1115, and it covers key commodities such as:

• soybeans
  
• coffee
  
• wood and timber
  
• livestock and cattle
  
• palm oil
  
• rubber
  
• products derived from any of these
  

The updated proposal adjusts requirements for different types of businesses.

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1. Upstream operators

These are businesses exporting or placing goods on the EU market.

Under the new proposal:

• Only upstream operators must submit a Due Diligence Statement (DDS) when importing regulated goods through the EUDR IT system.
  
• "Micro and small operators" from low-risk countries only need to submit a one-off declaration.
  
• Moreover, these micro and small operators may now provide a postal address instead of GPS coordinates, easing a previously burdensome requirement.

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2. Downstream operators

These companies process or re-export goods, such as manufacturers and retailers.

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3. Traders

These distribute products within the EU market. Under the new proposals, downstream operators and traders are no longer required to submit DDS filings for EUDR commodities.

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New timelines and exclusions

The update also introduces extended timelines to give businesses more time to comply:

• Large operators and traders: obligations apply from 30 December 2026
  
• Micro and small enterprises: obligations apply from 30 June 2027
  

Additionally, the Parliament voted to exclude printed products, such as books and magazines, from due diligence obligations entirely.

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What does this mean for your business?

A key takeaway from the proposed changes is this:

→ Upstream operators must submit DDS filings, but they are not required to share their DDS reference number with downstream operators or traders. However, secondary operators and traders must still perform basic due diligence. In practice, this means that whenever you purchase EUDR-regulated products within the EU, you should ask your supplier:

1. Are you an EUDR operator?
   
2. If so, can you provide your DDS reference number?
   

If they are an operator, collecting their DDS reference number will help confirm their compliance. If they’re not an operator, no DDS reference is needed, but it will be helpful to document that check. Skipping this step could lead you to unintentionally fall out of compliance, because even though secondary operators are not required to file DDS through the EU's IT system, they still need to ensure that what they are purchasing is a compliant product.

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👉 If you want a data-driven overview of your potential EUDR exposure across your supply chain, you can book a free 30-minute consultation with our team. You’ll walk away with a clear, actionable overview of your situation and the next steps to take.