EUDR – up in the air

Last month we reported that a further delay to the EUDR was likely, after a one-year postponement was proposed. We noted that, if adopted, EUDR would be pushed back to 30 December 2026 (and 30 June 2027 for micro and small companies).

The EU Commission announced on 21 October that it does not support this ‘stop the clock’ approach, despite most member states calling for delay. It wanted to push ahead with EUDR, starting at the end of next month.

Then, on 19 November, the EU Council adopted its position, including postponement and some simplification proposals. The main elements are:

· Postponement – EUDR would apply from 30 December 2026 for medium and large operators and 30 June 2027 for small and micro-operators.

· The obligation and responsibility for submitting the required Due Diligence Statement (DDS) to fall exclusively on the operators who first place the product on the market.

· Downstream operators and traders to no longer have to submit separate DDSs, but only the first downstream operators must keep and pass on the reference number on the initial statement.

· Micro and small primary operators would submit only a one-off simplified declaration.

The Council will now start negotiating with the European Parliament in order to reach a final agreement before the current EUDR becomes applicable on 30 December 2025. In parallel, political parties in the European Parliament are preparing their amendments and the vote is scheduled for this week.

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