EUDR: Delay will only impact smaller operators

Illegal amazon deforestation drone panoramic aerial view, Mato Grosso, Brazil. Forest trees, soybeans agriculture field land. Concept of climate change, global warming, ecology, environment, nature.
The EUDR delay may not cover all companies (Getty Images)

Downstream operators will not be required to submit due diligence statements

The European Commission has updated its proposal on the upcoming delay to the European Union Deforestation Regulation (EUDR). With this update, the delay will only apply to smaller operators. Larger operators will be excluded.

The delay would apply to all small and micro operators, not just farmers. For these operators, the regulation will come into force in 30 December 2026 (rather than the current June 30 2026 deadline).

The European Commission will propose that the delay does not cover larger companies. For them, the regulation will enter into force on 30 December 2025, as originally planned, although they will have a grace period for checks and enforcement.

Before coming into force, the proposal will still need the approval of MEPs, as well as EU countries at the Council and co-legislators.

In September, the European Commission recommended a second year-long delay of the regulation. The reason given was that the IT systems were not ready.

However, some members of the European Parliament have already pushed back against the delay, arguing that the Commission has already had a year to fix IT systems.

No due diligence statements for downstream operators

Also part of the update to the Commission’s proposal is the announcement that downstream operators and traders will no longer have to submit due diligence statements.

Only one due diligence statement will be required for the entire supply chain, at entry into the EU market. The operator placing the product on the market will be responsible for this.

Furthermore, small and micro enterprises will only be required to submit a one-off due diligence statement, rather than submit regularly.

According to the Commission, this will enable to IT system to function more efficiently.