Progress in the Review of the European Deforestation Regulation (EUDR)

On November 19, 2025, the Council of the European Union agreed to begin negotiations to revise the Regulation on deforestation-free products, known as “EUDR.” This is a formal step that opens the door to discussions with the European Parliament to reach a final agreement and has significant legal implications for operators, traders, and regulators.

Regulatory Context

The EUDR Regulation, which has been in force since June 2023, requires all actors in the supply chain, such as producers, importers and intermediaries, to ensure that raw materials such as cocoa, coffee, soy, timber, rubber, beef and palm oil do not come from areas where deforestation or forest degradation has taken place.

Implementation was originally planned for December 30, 2024, but has already been postponed, giving operators and administrations more time to develop the systems needed to meet these new requirements.

Changes Proposed by the Council

According to the Council's negotiating mandate, several important modifications are proposed that seek to make legal compliance easier, lightening the administrative burden without losing sight of the main objectives of the Regulation.

• Uniform postponement:

  
  

  • For medium and large operators: the application of the Regulation is postponed until December 30, 2026

  • For micro and small businesses: an additional period is granted until June 30, 2027.

• Simplifying due diligence obligations :

• Only the operator who places the product on the market for the first time will be responsible for submitting the due diligence statement (the “first operator”).

• Downstream operators no longer have to file separate declarations; it is enough to keep and transmit the reference number of the initial declaration.

• Micro and small businesses will only need to submit a single simplified declaration, which greatly simplifies their reporting.

• Impact assessment:

• The European Commission is tasked with conducting a simplification study by April 30, 2026, focusing particularly on the administrative effects on micro and small businesses. Depending on the study's findings, further legislative proposals may follow.

Legal and Commercial Relevance

From a legal point of view, this mandate from the Council seeks to find a balance between two needs:

• Regulatory and environmental : maintain the commitment to avoid deforestation linked to products imported or destined for the European market.

• Operational viability : offering more time and simplifying processes so that operators (including the smallest ones) can adapt without facing excessive risks or excessive administrative costs.

For companies in the forestry or agricultural raw materials supply chain, this represents a positive sign: there is institutional recognition of the practical challenges involved in compliance, and European institutions are willing to adjust the regulatory regime to facilitate actual implementation.

Next Legal Steps

• Legislative negotiations : With the approval of the Council's mandate, negotiations with the European Parliament are expected to begin in the coming weeks.

  
  

• Formalization of changes : If an agreement is reached, the discussed adjustments must be formalized in legislative acts (regulations) before the new application date comes into effect.

  
  

• Monitoring compliance : Operators will need to prepare their traceability systems, due diligence, and comply with the new rules (or their simplification), using the additional time to avoid future penalties.

Recommendations for Clients

For our customers involved in supply chains subject to the EUDR (agribusiness, international trade, raw material value chains):

• Assess readiness : Review your compliance processes, ensuring that the "first operator" is clearly identified.

  
  

• Anticipate the administrative impact : Think about how the proposed simplification could help reduce your reporting costs and times.

  
  

• Participate in the regulatory debate : Stay informed about the progress of negotiations between the Council and Parliament in order to try to influence, if appropriate, through sectoral associations or lobbying networks.

  
  

• Plan scenarios : Since the entry into force may be delayed, it is advisable to be prepared with different scenarios (original term vs. extended term) to handle operational and financial risks.

In conclusion, this Council-led review demonstrates a practical EU approach to achieving realistic environmental targets without compromising the operational efficiency of economic actors. For our clients, this presents an opportunity to strengthen their legal compliance with a more manageable regulatory burden.

We are ready to provide proactive support to companies in preparing and getting ready for the upcoming implementation of these regulations.

For more information, please consult the following link for updates on this review process undertaken by the Council of the European Union: https://www.consilium.europa.eu/en/press/press-releases/2025/11/19/deforestation-council-ready-to-start-talks-with-parliament-on-a-targeted-revision-of-the-regulation/