After weeks of uncertainty, the European Commission has now tabled its official proposal to amend the EU Deforestation Regulation (EUDR) – marking what in the past month looks like a double U-turn.
This is still only a proposal. The European Parliament and the Council will now examine and discuss the text under the ordinary legislative procedure, and both institutions must formally adopt the amendment before it can take effect. The Commission has urged the co-legislators to do so swiftly – ideally by the end of 2025 – to enable an extended implementation period.
At the same time, the Commission is preparing contingency plans to ensure that economic operators can still comply with their obligations should the amendment not be adopted in time. In that case, the current EUDR framework would enter into application as scheduled, on 30 December 2025.
The new proposal still targets adoption of the core regulation for medium and large companies by the end of this year, with a six-month grace period – and an additional six months for smaller entities.
Micro and small primary operators
A new sub-category – micro and small primary operators – would also be introduced, but only in low-risk countries. These operators would no longer be required to file full due-diligence statements (DDS). Instead, they would make a one-time simplified declaration to obtain a unique declaration identifier, which would then travel with the goods through the supply chain.
Where a Member State already captures equivalent data through its national system, that information could be directly transferred into the EU’s central EUDR system – allowing the operator to skip submitting the simplified declaration altogether.
Even though this simplification is formally designed to apply across all sectors, it is largely driven by the inclusion of cattle under the EUDR, where several Member States already operate established national traceability or licensing systems that capture much of the required data. This sector-specific reality is also one of the reasons why micro and small operators have been granted an extended implementation timeline until December 2026.
For this group alone, postal addresses could replace precise geolocation coordinates for the plots concerned – a further nod to administrative simplification for very small players operating in low-risk areas.
Downstream operators and traders
To allow for a more efficient use of the EUDR IT system, the Commission proposes that downstream operators and traders should no longer be obliged to submit due-diligence statements (DDS). With this streamlining, only one submission – made at the entry point to the EU market – would cover the entire supply chain. Reporting obligations and legal responsibility would thus remain focused on the operators placing products on the market for the first time.
At the same time, all downstream operators and traders, regardless of size, would still need to maintain full traceability by collecting and passing on DDS reference numbers and declaration identifiers throughout the supply chain.
Big companies (non-SME)
Non-SME downstream operators and traders must register in the EUDR Information System before placing, making available, or exporting relevant products. Registration is a legal prerequisite for larger entities, reflecting the Commission’s rationale that they have significant influence on supply chains and are critical for traceability and enforcement – particularly for risk profiling, checks, and customs integration.
These non-SME entities would also benefit from a six-month grace period before enforcement begins, allowing time to complete registration.
Timeline
Now → 30 Dec 2025: medium and big companies – are expected to complete their system connections, internal processes, and data models for due-diligence statements (DDS) by the end of the year. They would benefit from a six-month grace period before enforcement begins, giving them time to finalize technical integration and adapt compliance workflows under the revised framework.
30 Jun 2026: Competent-authority checks are set to begin after the initial implementation phase. Before that date, national authorities will be able to issue warnings and guidance notices rather than sanctions, giving operators a final opportunity to adjust systems and correct any compliance gaps ahead of full enforcement.
30 Dec 2026: Micro/small operators’ obligations kick in
How Pantiko helps
Pantiko can support you under both models – today’s framework and the proposed one:
- Automate DDS creation on behalf of operators such as forest owners.
- Verify incoming DDS data to ensure that what you receive is correct and valid.
- Automate DDS creation and management when you are the operator yourself or importing to EU.
- Pass DDS numbers and declaration identifiers down the chain (and receive them from suppliers) without manual re-entry.
- Enable offline field capture and on-site printing, so identifiers and documents travel with the load (CMRs, delivery documents, etc.).
- Import data from national systems (where available) reducing redundant typing and mismatches.
Check out our EUDR solution site to learn more or other parts of our site to see how Pantiko can also support you beyond EUDR.