Deforestation and forest degradation currently represent one of the most significant challenges in environmental policy. In response, the European Union adopted legislation aimed at restricting the placement on the EU market of products associated with deforestation — Regulation (EU) 2023/1115 of the European Parliament and of the Council on the making available on the Union market and the export from the Union of certain commodities and products associated with deforestation and forest degradation, and repealing Regulation (EU) No 995/2010 (hereinafter the “EUDR”).
Following a postponement of its effective date from the end of 2024, the turn of 2025 brought further delays and changes to the EUDR. Under pressure from Member States, the Council of the European Union and the European Parliament approved a postponement of its application and additional substantive changes, which were incorporated into Regulation (EU) 2025/2650 of the European Parliament and of the Council amending Regulation (EU) 2023/1115 (EUDR) (hereinafter the “EUDR Amendment”). Below we summarize the most significant changes introduced by the EUDR Amendment.
EUDR in a nutshell
The EUDR aims to ensure that the commodities listed therein originate only from areas where deforestation has not occurred after 2020. The regulation therefore establishes requirements for companies placing on the EU market, supplying on the EU market, or exporting from the EU certain commodities (cocoa, cattle, coffee, oil palm, rubber, soy, and wood) or products containing these commodities.
The scope of obligations is differentiated based on the size of the undertaking and its role within the supply chain. For companies dependent on imports of the relevant commodities, this may result in a substantial expansion of regulatory obligations and a significant administrative burden.
Impacts can be expected, for example, for manufacturers of furniture and paper products (in connection with wood), producers of tyres and other rubber products, manufacturers of wood-based construction materials, or companies using palm oil and its derivatives in the chemical, cosmetics, or energy industries. Increased requirements will also affect feed manufacturers and livestock producers, who will be required to systematically trace and document the origin of soy used in animal nutrition, as well as other entities within supply chains that will need to demonstrate the origin and traceability of the raw materials used.
Obligations of economic operators
Under the EUDR, economic operators are required to exercise due diligence with respect to relevant commodities. This includes collecting relevant information, carrying out risk assessment measures, implementing risk mitigation measures where necessary, and submitting annual reports on the due diligence system and the measures adopted.
The information that operators must collect includes a description of the relevant commodities and products derived from them, the date or time range of production, the quantity of relevant products, the country of production, the geolocation of all plots of land where the commodities were produced, the name, postal address and email address of the undertaking or entity supplying the products, and adequately conclusive and verifiable information demonstrating that the products are deforestation-free and produced in accordance with the relevant legislation of the country of production.
Operators must carry out a risk assessment based on the risk level of the relevant country in accordance with Article 29 EUDR (high, standard, or low risk). The EUDR Amendment introduced a new category of countries classified as “low risk” of deforestation, for which a simplified due diligence regime will apply. If the risk assessment indicates that there is more than a negligible risk, operators must implement risk mitigation measures, such as requesting additional documentation, conducting independent audits, or adopting other appropriate measures. Large undertakings should also appoint a person responsible for ensuring compliance with the EUDR. All decisions regarding procedures and measures must be documented and, where necessary, made available to the competent authorities.
Postponement of EUDR obligations for individual entities
Large and medium-sized undertakings will now be required to comply with EUDR obligations only from 30 December 2026, while micro and small undertakings will be subject to the obligations from
30 June 2027. At the same time, the regulation introduces a “transition period” from 30 December 2026 to 30 June 2027, during which the obligations will formally apply, but enforcement actions will be carried out only on the basis of specific complaints. Instead of financial penalties, companies will primarily be required to remedy any deficiencies identified.
While this relief provides affected sectors with additional time for preparation, companies are nevertheless advised not to delay their preparations. The collection and validation of the necessary data is a process that cannot realistically be completed within a few weeks. Companies capable of delivering a complete EUDR data package will gain a significant competitive advantage.
Simplified due diligence procedure
In addition to postponing the regulation’s application, the EUDR Amendment introduced several substantive changes intended to reduce the burden on both large manufacturers and local producers.
The newly introduced simplified due diligence procedure allows operators to skip the risk assessment and risk mitigation steps and instead perform only information collection and submit a single simplified due diligence statement. However, this simplified procedure is only available when sourcing from countries classified by the EU as low-risk countries, and provided there are no substantiated concerns that the product could contribute to deforestation in the relevant areas.
New categories of entities
Under the original EUDR rules, the main obligations would have applied somewhat illogically even to downstream entities and traders. The amendment therefore introduced additional categories of entities, namely downstream operators and a new subcategory of micro and small primary operators.
A downstream operator, within the meaning of the EUDR Amendment, is a person placing on the EU market or exporting from the EU relevant products manufactured using relevant commodities already covered by a due diligence statement — in other words, companies further down the supply chain that are not the first to place the commodities on the market. Downstream operators are not required to verify whether due diligence has been carried out nor to submit a new due diligence statement, which significantly reduces reporting requirements and the number of interactions with the EU information system. Nevertheless, they must collect and retain information regarding the relevant commodities and products, including information about the suppliers (name, trade mark, address, email, website, and due diligence statement identifier).
The obligation to collect and retain reference numbers should apply only to the first downstream operator or trader. In practice, this means that if a company purchases a relevant commodity from another entity within the EU that has already placed it on the market with a due diligence statement, it does not need to repeat the entire due diligence process.
A micro or small primary operator, according to the amendment, is a natural person or micro or small enterprise established in a country classified as low risk under the EUDR that places relevant commodities or products on the market or exports products that it produces itself in that country.
These entities benefit from a simplified regime, under which they must submit only a one-off simplified due diligence statement, for which a specific statement identifier will be issued and will accompany the relevant products. Micro and small operators must also inform competent authorities and other supply chain actors about potential risks of non-compliance with the EUDR and cooperate during inspections, including providing information enabling other supply chain actors to demonstrate that due diligence has been performed.
The one-off simplified due diligence statement is now included in Annex III of the EUDR. Its key difference from the standard due diligence statement lies in the possibility to provide only an estimated annual quantity of relevant products intended to be placed on the market or exported and to submit only the postal address of the facility or plots of land where the commodities are produced, rather than precise geolocation coordinates.
Narrowing the Scope of Relevant Products
The regulation also introduces a relatively small but significant adjustment for certain sectors concerning the scope of relevant products. Certain printed products (such as books, newspapers, and magazines) have been removed from Annex I of the EUDR, as their production and marketing were assessed as presenting minimal deforestation risk. However, the original list of relevant commodities (wood, cattle, cocoa, coffee, palm oil, natural rubber, and soy) remains unchanged.
Challenges for the Coming Year
The postponement of the EUDR’s application has produced mixed reactions. Large corporations have already invested considerable resources in monitoring systems and certification processes. Smaller companies, by contrast, may welcome the reduced burden and the delayed introduction of the new obligations.
Despite the one-year postponement, preparation efforts should not slow down. For larger corporations in particular, the coming year should be a period of intensive audits of supplier contracts, further refinement of internal processes, and gradual collection of relevant data. Companies will need to incorporate contractual clauses addressing responsibility for the accuracy of geolocation data and ensure compliance with all relevant EUDR obligations.
It is also important to remember that postponement does not mean cancellation of the EUDR obligations. The cut-off date of 31 December 2020, which determines whether deforestation has occurred, remains unchanged. Any raw material originating from land cleared after that date will become unsellable on the EU market once the system becomes fully operational in 2027.
Conclusion and Outlook
The postponement introduced by the EUDR Amendment provides companies with additional time to implement due diligence processes, revise contractual documentation, and deploy technological solutions for collecting and verifying geolocation data. At the same time, it prolongs a period of legal and commercial uncertainty, particularly regarding the classification of countries according to deforestation risk and the practical functioning of the EU information system.
Affected companies should therefore view the postponement not as a reason to delay preparations, but as a strategic opportunity to strengthen their compliance frameworks and supply chain management. Systematic verification of raw material origins, revision of supplier relationships, and the implementation of internal control mechanisms capable of withstanding regulatory inspections will be essential.
Entities that manage to integrate the new requirements into their business strategies early and effectively may gain not only regulatory certainty but also a competitive advantage in a market where transparency regarding the origin of commodities will increasingly determine commercial success.
Mgr. Jakub Málek, Managing Partner – malek@plegal.cz
Mgr. Kateřina Musilová, Associate – musilova@plegal.cz
26. 3. 2026