The EU extends the application of the EUDR Regulation until December 2026

The application of EU’s antideforestation law, known as EUDR, has officially been delayed again until the end of 2026.

Although at the end of 2024 the application of Regulation (EU) 2023/1115 on deforestation-free products imported into the EU was postponed until 30 December 2025, Regulation (EU) 2025/2650 of December 2025, establishes a further delay in the application of the articles relating to the main obligations of operators until 30 December 2026. In the case of natural persons and micro and small enterprises compliance will be required from 30 June 2027.

This Regulation also clarifies definitions, adjusts due diligence obligations, and amends provisions relating to review and deadlines, while preserving its fundamental environmental goals and reducing disproportionate burdens on small operators.

What are the main changes?

Introduction of two new categories of actors different from the "operator"

Regulation (EU) 2025/2650 updates the definition of operator and creates two new categories that change how obligations are distributed within the supply chain.

The term “operator” refers to any natural or legal person who places relevant products on the EU market or exports them, excluding “downstream operators”. This new category and that of “micro or small primary operators” are covered in this Regulation:

• “Micro or small primary operator" means a natural person or micro or small enterprise, under EU accounting rules, established in a low-risk country which places on the market or exports the regulated products this operator itself has grown or obtained.
• "Downstream operator" means a natural or legal person who, during a commercial activity, places on the market or exports regulated products manufactured from regulated materials, all of which are covered by a due diligence declaration or a simplified declaration.
  Processors and exporters will be considered downstream operators depending on their role in the supply chain:
  • Processors if they take relevant products that have already been subject to due diligence and use them to make other relevant products that they then place on the market or export.
  • Exporters when they export products that were manufactured from relevant products already covered by a due diligence statement or simplified declaration.

Changes in operators' obligations

The Regulation provides for the following modifications to the obligations of operators:

• The obligation and responsibility to submit the due diligence statement lies exclusively with the operators who first place the product on the market. They must keep and transmit the reference number of the initial declaration.
• Operators and traders downstream in the supply chain no longer have to submit their own due diligence statements, they must instead collect and retain the reference number of the initial declaration made by the primary operator.
• Micro or small primary operators in low-risk countries must submit a single simplified declaration in the Information System, the content of which is established in the new Annex III.
• Downstream operators and traders "other than SMEs" will not have to file returns but will need to register in the Information System.
• Regardless of size, all operators will collect and retain (for 5 years):
  • data of the operators, downstream operators or traders who have supplied them with the relevant products,
  • details of downstream operators or traders to whom they have supplied the relevant products.
    
    

Application

The application of Regulation (EU) 2023/1115 is planned as follows:  

Practical impact on commercial operations involving relevant products

The new delay and updated rules should make it easier to understand and apply Regulation (EU) 2023/1115, leading to a smoother transition where all companies will have one more year to:

• review commercial arrangements,
• finalize geolocation data,
• validate supplier datasets,
• train compliance teams and
• improve IT due diligence systems

New measures also aim to reduce impact and administrative burden on micro and small operators.

Now businesses must check what has changed, adapt their systems, and prepare for the new deadlines so that they comply with the rules when they come into force.

Further information:

• EU Commission – DG Environment: Regulation on Deforestation-free Products
• Regulation (EU) 2023/1115 on Deforestation-free Products
• Regulation (EU) 2025/2650 of the European Parliament and of the Council amending Regulation (EU) 2023/1115 
• Deforestation law: Parliament adopts changes to postpone and simplify measures