EUDR Dec 2025 Amendments: What SMEs Need to Know
The December 2025 Update: Extended Timelines & Simplified Requirements
On December 17, 2025, the European Parliament formally adopted amendments to the EU Deforestation Regulation (EUDR) that fundamentally reshape the implementation timeline and ease compliance burdens for certain operators. This represents the second postponement of the regulation, which was originally scheduled to take effect on December 30, 2024. The amendments, formally adopted as Regulation 2025/2650, entered into force on December 23, 2025
Key Changes at a Glance
The most visible change is the one-year postponement:
Large and medium operators and traders: Must comply by December 30, 2026
Micro and small enterprises: Must comply by June 30, 2027 (unless already covered by the EU Timber Regulation, in which case the deadline is December 30, 2026)
This extended timeline applies regardless of whether a company is an "operator" (first placing relevant products on the EU market) or a "trader" in the supply chain.
New Category: Downstream Operators
The amendments introduce an important new classification: downstream operators. These are companies that place products on the market using commodities that have already been proven deforestation-free through a due diligence statement or simplified declaration from their supplier. Examples include a chocolate manufacturer using certified-deforestation-free cocoa, or a furniture maker using timber covered by a simplified declaration.
Downstream operators are exempt from submitting full due diligence statements, a significant administrative relief. Instead, they must:
Collect and retain reference numbers of due diligence statements from their suppliers for five years
Maintain supplier information (name, address, contact details)
Register in the EU Information System if they are non-SME downstream operators
For SME downstream operators, registration requirements are even lighter.
Simplified Declaration for Micro and Small Primary Operators
Micro and small enterprises that produce and first place relevant products on the EU market in low-risk countries can now submit a one-time simplified declaration instead of repeated due diligence statements. This replaces detailed geolocation data with postal addresses of production plots, significantly reducing administrative complexity.
Printed Products Excluded
An important clarification: printed products (books, newspapers, printed images) are now explicitly excluded from EUDR scope.
What Hasn't Changed
The core environmental objectives of the EUDR remain entirely intact. Companies that first place relevant products on the EU market (primary operators) must still:
Conduct full due diligence to prove products come from deforestation-free sources
Collect geolocation data (geodata coordinates) for all production plots
Perform risk assessments based on country and commodity classification
Implement risk mitigation measures where necessary
Submit due diligence statements via the EU Information System
This is not a weakening of environmental protections—it's a targeted simplification designed to make compliance more practical while protecting forests.
What This Means for SMEs: Practical Implications
Timeline Advantage: 2026 is Your Preparation Year
If your SME doesn't already fall under the EU Timber Regulation (EUTR), you have until June 30, 2027 to achieve full compliance. This is not a reason to wait—it's an opportunity to build robust processes:
Audit your supply chain now: Map your suppliers and identify where your commodities originate. If you source cocoa, coffee, soy, beef, timber, palm oil, or rubber (or products containing these), you need to know your supply chain.
Classify your role: Determine whether you are a primary operator (placing products on the market for the first time) or a downstream operator (purchasing already-compliant products). Your obligations differ significantly.
Select your suppliers carefully: If you're a downstream operator buying from certified suppliers, you'll have minimal obligations. If you're a primary operator, you'll need suppliers who can provide detailed traceability data.
Prepare for the EU Information System: You'll need to register and submit documentation through the official EUDR portal. The system has faced technical challenges, and the Commission's assessment report (due April 30, 2026) may bring improvements.
For Downstream Operators (Likely the Majority of SMEs)
The amendments dramatically simplify requirements for downstream SMEs. If you manufacture products using commodities that your suppliers have already verified as deforestation-free, you primarily need to:
Keep supplier contact information and due diligence reference numbers on file
Request these reference numbers from all suppliers
Cooperate with authorities if they have concerns about non-compliance
You do not need to independently verify the deforestation status of your inputs or submit your own due diligence statements.
For Primary Operators (Sourcing from Abroad)
If you import commodities directly or are the first to place relevant products on the EU market, full due diligence remains mandatory:
Geolocation data collection: You must know the exact coordinates of the plots where your commodities originate
Risk assessment: Use the EU's country risk classifications (low, standard, high) to assess deforestation risk
Supplier documentation: Maintain contracts and documentation proving no deforestation occurred after December 31, 2020 (the regulatory cutoff date)
Due diligence statement submission: Submit via the EU Information System by your application deadline
The extended timeline gives you 12 months to establish these systems rather than having to do so immediately.
The April 2026 Review: Stay Alert
The European Commission is conducting a mandatory "simplification review" due April 30, 2026, focused on administrative burden and potential improvements to the Information System. While this doesn't automatically mean further changes, companies should monitor this assessment closely. It may clarify ambiguous requirements or introduce additional simplifications.
Bottom Line: Prepare, Don't Procrastinate
The December 2025 amendments represent a genuine attempt to balance environmental protection with implementation reality. For SMEs, the extended timeline and simplified downstream operator status are substantial reliefs. But the extended deadline should be seen as an opportunity to prepare properly, not a reason to delay.
Start now by understanding your role in the supply chain, auditing your suppliers' documentation capabilities, and planning your registration and submission processes for the EU Information System. By December 30, 2026 (or June 30, 2027 for micro and small enterprises), full compliance will be mandatory—and any company found placing non-compliant products on the EU market faces enforcement action from member state authorities.
The forests the EUDR protects matter. So does your business's ability to operate smoothly within this new regulatory landscape.
EUDR Services
We can help with all the above and more. Should you have any questions, concerns or would like to discuss EUDR in general, do not hesitate to get in touch with us. Email us at: questions@eudrservices.com
Official EU Resources
For authoritative guidance and updates, consult these official sources:
European Commission - Environment
The primary hub for EUDR policy, guidance documents, and implementation resources. Includes FAQs, factsheets for SMEs, and links to the EUDR Information System.
EU Green Forum - Deforestation Regulation Implementation
https://green-forum.ec.europa.eu/nature-and-biodiversity/deforestation-regulation-implementation_en
Official implementation guidance and updates on compliance requirements, including the latest clarifications on downstream operators and SME obligations.
European Parliament News - December 2025 Amendments
Official parliamentary statement on the adopted amendments, explaining the rationale and key changes.
EU Official Journal - Regulation 2025/2650
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R2650
The full legal text of the amending regulation (published December 23, 2025).
EUDR Information System Portal
https://ec.europa.eu/environment/ecat/
The official portal where operators, traders, and their representatives must register and submit due diligence statements.
References
Earth.org, "EU Deforestation Regulation Postponed By One Year, Again," December 22, 2025
Stibbe, "The amended EUDR: what has changed and what has remained," December 29, 2025
European Parliament, "Deforestation law: Parliament adopts changes to postpone and simplify measures," December 16, 2025
FoodChainID, "Preparing Quality Managers for Stress-free Implementation," January 4, 2026
Stibbe analysis of Regulation 2025/2650, December 29, 2025
EU Green Forum, "Deforestation Regulation implementation," December 29, 2025
European Parliament press release, December 16, 2025
Regulation 2025/2650, Article amendments on scope
OSApiens, "EUDR Update Dec. 2025: What changes for companies?" December 28, 2025
Stibbe and Inside Energy & Environment, December 2025
OSApiens and Global Compliance News, December 2025 - January 2026
EU Green Forum, "Deforestation Regulation implementation"
OSApiens analysis and Stibbe analysis, December 2025
Inside Energy & Environment, "EU Deforestation Regulation Postponed and Simplified," December 16, 2025