EUDR: the Commission announces another revision of the law, following two postponements

Fewer due diligence obligations and a change of scope: main elements of the EUDR revision

Change in the scope of the EU Deforestation Regulation

A draft delegated act changes the product scope of the EUDR. "The regulation covers the commodities most associated with deforestation or forest degradation, including cattle, cocoa, coffee, palm oil, rubber, soy, wood, and certain products made from these."

The draft excludes "several products of the scope, such as leather or retreaded tyres, and exempts several others, such as product samples, certain packing materials, used and second-hand products, and waste."

But there have been more inclusions than exclusions overall, according to the Commission.

"The draft includes proposed additions of certain downstream products, such as soluble coffee and certain palm oil derivatives."

The fact that leather and tyres are now out of the scope of the EUDR, even though they are drivers of deforestation, was justified by the Commission by the fact that, beyond the environmental benefits, other elements must be taken into account. The risk of "deforestation relocalisation" and "asymmetries in the value chains", for instance, the anticipated difficulty operators would have to obtain information required to comply with EUDR from suppliers outside the EU market, as well as additional compliance costs.

It specifies that the draft delegated act is open for public feedback until 01/06/2026.

What does the report to the European Parliament and Council contain?

This report describes the simplification measures implemented by the European Commission on this file since 2023 and the newly introduced ones, including the benchmarking of a wider low-risk category of countries with simplified due diligence requirements. The "high-risk" countries, in terms of deforestation, are Belarus, Myanmar, North Korea, and Russia. The U.S. and China are classified as "low-risk" countries, while Brazil and Indonesia fall in the "standard risk" category.

The Commission is putting forward the fact that these measures "are expected to reduce annual compliance costs for companies subject to EUDR obligations by about 75%, compared to the original EUDR."

It also points out that the EUDR, despite the fact that it never entered into force, "is already contributing to structural changes in global supply chains, with increased investment in traceability and more transparency and efforts into the preparations of complying with the law."

The report also includes "trade facilitation tools, like repositories of legislation of producing countries and a repository of certification schemes for commodities".

A guidance document for stakeholders

The guidance provides "further clarification on obligations for the downstream supply chain" and on "the very simplified specific regime applicable to micro and small primary operators". A 'Frequently Asked Questions' document has also been released.

The key element of this guidance is that the obligation of the first downstream supply chain actor to collect and keep the reference numbers or declaration identifiers becomes a "passive obligation", so they don't actively need to investigate their suppliers or actively request information, contrary to the mandatory due diligence requirements of the first version of the EUDR.

Changes to the implementing act for Member States

The draft implementing act on the Information System has been updated and requires Member States' approval before it can be adopted. It includes:

• a simplified declaration form for micro and small primary operators, aligned with the existing due diligence statement format;

• updated specifications for the automated application interfaces;

• a contingency plan for unplanned unavailability;

• and a voluntary grouping feature introduced in response to requests from the business sector.

The implementing act also sets out that "companies that place the listed products on the EU market for the first time, or export them, must be able to show that the products are deforestation-free" or that they are "produced in line with relevant laws in the country of production".

What happened to the EU Deforestation Regulation in 2025 and 2024?

The European Deforestation Regulation was adopted in 2023, but never entered into force.

In September 2025, the European Commission alerted that "an IT technical problem" was preventing the launch of the EUDR declaration platform on 30/12/2025. It was the second time the Commission postponed the entry into force of this regulation, but it assured that it could not have known in October 2024, at the last postponement, that the IT system would not be able to process the quantity of declarations by operators, as pre-deployment actions had not begun. The first postponement was intended "to allow companies sufficient time to comply with the regulation".

On 04/12/2025, the Council and Parliament reached a political agreement to postpone the entry into force of the European Deforestation Law by one more year. On 17/12/2025, the vote of the Parliament confirmed that it will defer the EUDR until 30/12/2026 or 30/12/2027, depending on the size of the company, and that it was in favour of simplifying some due diligence requirements.