EUDR Delay or Grace Period?

European Commission Proposes Adjustments to EUDR Implementation

After suggestions that EUDR might be postponed by 12 months, the European Commission has announced an EUDR implementation update 2025 including set of targeted amendments to the EU Deforestation Regulation aimed at simplifying implementation and easing the administrative burden for smaller operators and downstream supply chains.

Rather than introducing a full 12-month delay to implementation, the Commission’s proposal focuses on simplification and phased entry into force to ensure the EUDR IT system can operate effectively and accommodate all users.

Key elements of the proposal

Large and medium-sized companies

• The EUDR will still apply from 30 December 2025.

• A six-month grace period is proposed for checks and enforcement to allow for a smoother transition.

Micro and small enterprises

• Their application date would be postponed to 30 December 2026.

• This extension recognises the additional time smaller operators may need to adapt to the new requirements.

Micro and small primary operators from low-risk countries

• Will only be required to make a simple, one-off declaration in the EUDR IT system.

• If the relevant information already exists in a Member State database, no further action would be needed.

Downstream operators and traders

• Will no longer be required to submit due diligence statements (DDS) in the EUDR IT system.

• Only the operator placing the product on the EU market for the first time would need to submit a DDS.

• Downstream actors remain within the EUDR framework and must maintain traceability records and ensure their products are covered by an upstream due diligence statement.

Purpose of the proposed changes

The Commission stated that these measures are designed to:

• Reduce duplication and administrative costs, particularly for small operators.

• Ease pressure on the EUDR IT system, which is expected to face higher-than-anticipated data volumes.

• Ensure readiness of the system and stakeholders ahead of full implementation.

According to the Commission, these simplifications could reduce administrative costs by up to 30% for companies.

Next steps

EUDR implementation update 2025 remain proposals and must be adopted by the European Parliament and the Council before taking effect.
If the amendment is not approved in time, the current timeline will remain in place — meaning the EUDR enforcement  would apply from 30 December 2025 for all large companies.

For further details, you can read the European Commission’s announcement here. Or, book time to speak with our team here