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The European Commission has proposed ‘targeted simplifications’ that aim to ensure the smooth implementation of the upcoming EU Deforestation Regulation (EUDR).

The EUDR, first announced in 2021, has been developed to ensure that products sold in the EU do not contribute to deforestation. It will impact the sourcing of commodities such as palm oil, cocoa and coffee, aligning with the EU’s sustainable sourcing goals and broader climate-related ambitions.

Its implementation, however, has faced setbacks – initial deadlines were postponed from 2024 to December 2025, and the EU announced it would consider a further delay last month. These moves have drawn criticism from concerned stakeholders across the F&B supply chain, including environmental organisations and major food businesses.

The Commission cited complications with its IT platform, designed to manage compliance data, as the reason for proposed delays. However, this week (21 October 2025) it has put forward a new proposal for targeted adjustments designed to simplify the process and its impact on the IT system, aiming to ensure the EUDR can be successfully implemented this December.

The proposal, drafted up following feedback from stakeholders, aims to reduce obligations for downstream operators and traders that commercialise the relevant EUDR products once they have been placed on the market – such as retailers, or large EU manufacturing companies.

It also seeks to reduce the impact for micro and small primary operators from low-risk countries worldwide who sell their goods directly on the European market, which it says cover ‘close to 100% of farmers and foresters in the EU’.

Changes to due diligence reporting

The Commission proposes that downstream operators and traders should no longer be obliged to submit due diligence statements, with only one submission in the EUDR IT system required for the entire suppy chain, made at the entry point in the market.

For example, cocoa beans would need only one due diligence statement to be submitted by the importer bringing them into the EU. Downstream manufacturers of chocolate products using the beans would not be required to submit a new due diligence statement in the IT system.

Micro and small primary operators would only submit a simple, one-off declaration in the system. When the information is already available, for instance in a member state database, the operators do not have to take any action in the IT system themselves. This replaces the previous need for regular submissions of due diligence statements.

Transition period

The EUDR compliance deadline will remain 30 December 2025 for ‘large and medium’ companies – but they will benefit from a six-month grace period for checks and enforcement, to ‘ensure a gradual phase-in of the rules’.

Additionally, for ‘micro and small’ enterprises, the EUDR will enter into application on 30 December 2026.

The Commission said these new application dates, as well as the simplification of obligations, aim to ensure the IT system can sustain the level of expected loads following a ‘substantial reassessment’ of the projected impact on the system.

Next steps and industry response

The European Parliament and the Council will now discuss the Commission’s proposal and would need to formally adopt the targeted amendment of the EUDR before it can come into effect.

Teresa Ribera, executive vice president for Clean, Just and Competitive Transition, said: “This approach provides certainty and stability, streamlining the tracking process for micro and small producers who, while individually posing little risk, collectively provide critical data for maintaining overall traceability”.

“We offer a clear implementation schedule that ensures the regulation will take effect seamlessly starting end of this year, allowing large operators to progressively adapt while giving micro and small producers more time to adjust.”

The Rainforest Alliance released a statement of ‘relief’ in response to the European Commission’s clarification, commenting: “We commend the Commission for maintaining the implementation date of 30 December 2025 for large companies (though we have reservations about some of the arrangements proposed to facilitate compliance).”

The organisation described the earlier delay as “highly concerning,” expressing worry that the regulations would be “watered down even further”.

However, it called on companies and governments to ensure that smallholders are “meaningfully and adequately supported to adapt to the EUDR”.

“While the Commission has proposed some simplifications to benefit small operators in low-risk countries, in practice, that only helps EU forest owners and farmers – it does nothing for the majority of smallholder farmers who don’t fall in that category,” the Rainforest Alliance stated.

“We reiterate our call to action to also address collectively the specific challenges millions of smallholders face in producing EUDR-compliant products, and the disproportionate burden placed on their shoulders to do so – despite the fact that they are not considered operators under the EUDR.”

The World Wide Fund for Nature (WWF), however, described the move to simplify the EUDR as a “shameful surrender to political pressure”.

Anke Schulmeister-Oldenhove, senior forest policy officer at WWF European Policy Office, said: “Let’s be clear: proposing a partial delay and further changes is a deliberate choice, not an absolute necessity. It does not seem that the European Commission ever explored other options to fix any IT issues; it feels like the perfect scapegoat to water down the regulation.”

She added: “The Commission may win a few political points, but the losers are clear: companies that have invested in deforestation-free supply chains, and forests that will continue vanishing at a breathtaking pace”.

WWF is calling on the EU parliament and member states to uphold the regulation as initially agreed and “provide real support” for implementation.