EUDR Update Dec. 2025: What changes for companies? 

On December 17, 2025, the European Parliament and Council approved targeted amendments to the EU Deforestation Regulation (EUDR). These changes focus on easing implementation pressure while keeping the regulation’s core objectives intact. 
 
The result is more time and some procedural relief for certain actors, but no fundamental change in responsibility for first operators and importers. Understanding where obligations remain unchanged and where they have shifted is essential for planning compliance in 2026 and beyond.

Executive Summary

• Extended timelines: All companies are granted additional time to comply with the EUDR. While most companies have until December 30, 2026 to apply the regulation, micro- and small businesses have time until June 30, 2027. Specific exceptions apply to companies already covered by EUTR. 

• Core obligations remain unchanged: For operators who first place products on the EU market, due diligence, traceability and DDS submission requirements remain fully in place. 

• Targeted simplifications for downstream operators: A new category of downstream operators is introduced. Many downstream companies no longer need to submit a Due Diligence Statement (DDS), but traceability, supplier risk management and cooperation with authorities remain critical.

What does not change under the EUDR

Despite frequent speculation, the December vote does not represent a rollback of the EUDR. Companies that first place relevant products on the EU market remain fully responsible for ensuring deforestation-free and legal sourcing. Traceability requirements, including geolocation data for plots of land, risk assessment and mitigation measures, and the submission of DDS via the EU Information System remain central pillars of the regulation. The EUDR’s objective remains intact: to prevent deforestation-linked products from entering the EU market. 

Three common misconceptions regarding the EUDR

Before diving deeper, it is worth addressing recurring misconceptions in the market. 

• “The simplification review by April 30, 2026 will lead to further simplifications for all operators and traders.” 
  This is unlikely. The mandate for further simplification is targeted to small operators and the functioning of the EU Information System (TRACES). The European Commission has already shown reluctance to go beyond the current simplification proposal. 
  
  
• “Downstream companies have no obligations under the EUDR.” 
  Liability in downstream supply chains remains. Large downstream operators and traders must still register in TRACES. Measures such as product recalls or prohibitions on making products available on the market may be directed at any large operator or trader in the chain. Supplier risk management and traceability therefore remain essential. 
  
  
• “Traceability requirements have been removed from the EUDR.” 
  Traceability remains a legal obligation for first operators. In addition, first downstream operators and traders must collect and record reference numbers, which makes traceability a practical requirement for them. Beyond formal obligations, traceability remains critical for effective risk management, especially to limit recalls or address substantiated concerns.
  For companies that have already implemented traceability and due diligence workflows, these amendments typically reduce downstream administrative friction rather than making existing processes obsolete. For many osapiens customers, this mainly means that DDS submission workflows are no longer required for certain downstream roles, while aggregations, risk management procedures and data structures remain valuable and usable. 

Latest EUDR amendments: a closer look

Since the EUDR entered into force, companies across industries have been preparing for its far-reaching requirements. The vote on December 17, 2025 responds to feedback on implementation challenges, in particular concerning the EU Information System. Below, we break down the most relevant changes and what they mean in practice. 

In short, some processes have been simplified, but the substance of the EUDR remains unchanged, especially for companies closest to market entry. 

EUDR deadlines: Who must comply in 2026 and 2027

The most visible outcome of the December 2025 amendments is the revised application schedule. Large and medium-sized companies must comply with the EUDR by December 30, 2026. Micro- and small enterprises benefit from an extended deadline until June 30, 2027, unless they already fall under the EU Timber Regulation (EUTR). For companies that are not yet fully prepared, this extension offers valuable breathing room. However, it should be seen as an opportunity to build robust processes rather than a reason to postpone compliance efforts. 

Introduction of new roles and obligations

The amendments further clarify roles along the supply chain while keeping primary responsibility with those closest to the point of import or first placement on the EU market. 

• First Operators (those first placing relevant products on the EU market): 
  Obligations remain unchanged. Companies must maintain a full due diligence system, collect detailed traceability data, including geolocation, assess risks, implement risk mitigation measures where necessary, and submit a DDS to the EU Information System. 

• First Downstream Operators or Traders (the direct buyer from the first operator): 
  The administrative burden is reduced, as no independent DDS submission is required. Key tasks include collecting upstream reference numbers and maintaining full traceability from inputs to outputs. In practice, many first downstream operators can keep their EUDR processes largely unchanged, but no longer need to submit their own DDS. 

• Further Downstream Operators or Traders (subsequent entities in the chain): Requirements are further simplified. The focus is on storing supplier contact details (name, address, email) and cooperating with authorities where required. Large downstream operators and traders must register in TRACES and retain limited liability in cases of substantiated concerns. Strong supplier due diligence remains recommended to understand supply chain exposure and appropriately assess the risk of substantiated concerns. 

• Non-EU Suppliers (unless acting as importers): 
  There are no direct obligations under the EUDR. However, providing accurate and timely data, such as geolocation and production details, is essential for their EU customers’ compliance. Automating these data flows can streamline processes and help strengthen partnerships. Having strong EUDR capabilities in place can help them get market access to EU customers and gain a competitive advantage. 

Many companies operate in mixed roles, depending on the transaction. For example, a company may act as an operator when importing, but as a downstream trader when sourcing within the EU. Flexible, automated systems that account for these role changes are therefore essential for scalable compliance and audit readiness.

Simplification review to focus on small operators and EU TRACES

The amendments require the European Commission to publish an assessment by 30 April 2026 on administrative burden and implementation impact. The focus will be on small operators and potential improvements to the EUDR Information System (TRACES). 

This is an evaluative report only. There is no automatic commitment to further legislative changes. Given its limited scope, most companies should not expect major requirement reductions and should instead use the extended timelines to establish robust processes now. 

Simplifications for small and micro enterprises

Targeted relief applies to small and micro primary operators located in low-risk countries: 

• One-time simplified declaration via TRACES 

• Possibility to replace precise geolocation with postal addresses of plots 

These simplifications do not apply to operators in medium- or high-risk countries, who must follow standard due diligence and DDS submission requirements.

Exports and re-imports

Exports are simplified: in most cases, no separate DDS submission or explicit customs references are required. However, maintaining full traceability records remains advisable. If products are re-imported into the EU, the new importer will need complete datasets to submit compliant documentation.
 

Transition from EUTR to EUDR

The EU Timber Regulation (EUTR) remains applicable until the revised EUDR dates take effect. This avoids regulatory gaps for timber and timber-based products during the transition period. 

Exemption for printed products 

Printed products such as books, newspapers and printed images are removed from the scope of the EUDR. This affects companies dealing with CN chapter 49 products (“CN 49 ex”). However, many companies in publishing and print-related industries remain in scope due to other procurement or import activities, particularly related to wood or packaging materials. 

What the EUDR update means for your business

For importers and first operators, the message is clear: full compliance is still required, but there is now more time to get it right. This is the moment to move away from fragile, manual “deadline solutions” and toward scalable, automated processes that can withstand audits, volume increases and supplier changes. 

For downstream operators, understanding your exact role in each transaction is essential. Even without DDS submission obligations, structured traceability and supplier risk management remain critical for limiting liability and responding to substantiated concerns. 

Across industries, many companies are using the additional time to strengthen existing processes rather than slowing down. Those that invest now in stable, automated compliance foundations will be better positioned not only for the EUDR, but also for future regulatory and digitalization requirements.

How companies should prepare for the EUDR in 2026 

• Assess your position: 
  Review products, roles (operator vs. downstream, small- and micro operator status) and identify gaps with a structured checklist. 
  
  
• Prepare thoughtfully: 
  Use available resources, such as EUDR readiness checklists, to assess requirements without commitment.
  
  
• Choose solutions wisely:
  Look for solutions that automate all core EUDR processes in one centralized system while remaining modular for future regulatory changes. 
  

• Build for the long term: 
  Prioritize core compliance first, then layer in advanced automation for efficiency and audit readiness. 
  

• Test in real-world conditions: 
  Validate supplier and customer interactions and ensure automations work under operational pressure. 

Companies that already have an EUDR solution in place should build on their existing setup beyond pure compliance, for example by using established data structures and workflows for supplier management, other regulatory requirements, and broader digitalization initiatives. 

If you would like to discuss how these updates affect your specific setup, we are available to support you.

Talk to an expert.