EUDR Amendments: Insights Before the Final Vote
What Are The Implications of Parliament’s Vote on 26 November 2025?
The latest round of amendments to the EUDR marks the most significant shift in the Regulation since its adoption. Companies were already adapting to a complex and fast-moving framework.
Still, the recent postponement, new exemptions, and far-reaching simplifications fundamentally reshape both the timeline and the obligations for operators, traders, and competent authorities.
Beyond the headline delay, Parliament’s vote introduces structural changes that directly affect due diligence, data requirements, and the scope of products regulated. It also opens the door to yet another revision in 2026, creating a landscape where compliance strategies must remain agile and evidence-based.
This article breaks down what has changed, what uncertainties remain, and how businesses should interpret the evolving rules. With the next plenary session set to define the final direction, organisations need clarity now more than ever to prepare for an environment where expectations, timelines, and enforcement mechanisms continue to shift.
The New EUDR Timeline & Scope
EUDR Postponement & Grace Period
The most impactful amendment introduced by the Parliament, and earlier by the Council, is the EUDR delay. The approved text postpones the EUDR by 12 months, making it start applying:
- To large and medium primary operators, downstream operators, traders, and competent authorities from 30 December 2026,
- To micro and small primary operators, downstream operators, and traders from 30 June 2027.
The Commission wanted to introduce a grace period to let companies test the TRACES system and submit the DDS without checks or sanctions from the competent authorities. The checks would have been conducted after 30 June 2026 over medium and large companies, and after 30 December 2026 over micro and small companies.
But with the new application dates suggested by the Parliament, it is now clear that there is no room for a testing period. The competent authorities will get the green light to start their activities from the same dates the Regulation will start applying.
The Transition Plan From EUTR to EUDR
The only exception to the timeline mentioned above is the products subject to the EU Timber Regulation (EUTR), which follow a separate transition plan.
The general provision updates the repeal date from 30 December 2025 to 30 December 2026. However, there are some clarifications to the entry into application of the EUTR:
- With the harvest date before 29 June 2023, and the date of placing in the market from 30 December 2026: EUTR applies until 31 December 2029, then EUDR will replace it.
- With the harvest date before 29 June 2023, and the date of placing in the market from December 31, 2029: EUDR applies right away.
In addition, the previous plan provided a different transition plan for micro and small companies, but this was deleted in the Parliament’s proposal, probably because these companies had already received extra time thanks to the postponement. This means that no difference in provisions is made based on the company size.
The Printing Industry Completely Exonerated
One amendment that was proposed and approved by the Parliament, and that was difficult to predict, has been the complete exclusion of the printing industry from the scope of the Regulation.
The amendment exonerates all products under the HS code “ex 49” referring to “printed books, newspapers, pictures and other products of the printing industry, manuscripts, typescripts and plans, of paper” (see Annex I of EUDR).
EUDR Could Be Amended Again In 2026
The Parliament has required the Commission to carry out a simplification review and present it to the other EU institutions by 30 April 2026. If the second postponement and the constant changes to the EUDR, both in 2024 and in 2025, did not confuse companies enough, there could be additional changes before the end of April next year.
The review should cover the following topics: the administrative burden and the impact of EUDR, especially for micro and small operators in general, and solutions to the identified concerns, if any, including IT issues.
The Primary Operators
Updated Definition Of Micro & Small Primary Operators
The Parliament has not only recognised the introduction of the new category of companies, namely the micro and small primary operators, but it has also extended its definition.
Micro and small primary operators are now defined as natural persons or micro- or small-sized enterprises based in a low-risk country and placing on or exporting from the EU market the relevant products which they produce themselves in that low-risk country. Based on the EU Commission’s official press release, this definition covers almost 100% of the farmers and foresters acting in the European territory.
With the Parliament vote, the definition is extended to companies that normally exceed at least two of the standard size thresholds in EU company law (balance sheet total, net turnover, number of employees), but can prove that, specifically for the activities covered by the EUDR, the figures for those same three criteria do not exceed at least two of the thresholds.
A Simplified Declaration Instead Of The Due Diligence Statement
The Parliament approved the simplification for micro and small primary operators to be exempted from conducting a full due diligence and from submitting the due diligence statement to TRACES.
These companies are only required to submit to TRACES a simplified declaration that displays all information reported in Annex III. The amendments stressed the fact that the simplified declaration is a one-time effort, and it should not be thought of as a documentation submitted repeatedly, like the due diligence statement.
This declaration must be provided before placing the products in the market. TRACES will not return reference and verification codes as it would for a due diligence statement, but instead a “declaration identifier”.
The Parliament also introduced two additional provisions to simplify this task even more:
- The simplified declaration must be updated only in case of major changes.
- The simplified declaration can contain the estimated quantity of products.
Additionally, it is confirmed that micro and small primary operators can use the postal address of the relevant land plots (and establishments in case of cattle) instead of using the geolocation coordinates as in GeoJSON files. However, the postal address must correspond precisely to the location of the plots or establishments concerned.
As reported also in the Commission’s proposal, if a Member State already maintains country-level databases containing the information needed for simplified declarations, it may upload this data into TRACES on behalf of micro and small primary operators.
Maintained Requirements For Medium & Large Primary Operators
The Parliament vote did not bring any update to the requirements for medium and large companies, and instead approved the provisions from the Commission. This means that medium-sized companies will not benefit from the simplification allowed to the micro and small primary operators, but they will share the same requirements as the large companies.
Such requirements include:
- Conducting full due diligence through application of Articles 9, 10, and 11 (Data Collection, Risk Assessment, and Risk Mitigation).
- Submitting the due diligence statement (DDS) to TRACES.
- Passing the DDS reference and verification numbers to the downstream operators and traders.
Let’s see in the next chapter what the news is for these other groups of companies.
The Downstream Operators And Traders
Updated Definition Of Downstream Operators And Traders
Concerning the downstream operators and the traders, the definition was clarified by the Parliament to include exporters and placers on the EU market, which should include both domestic companies and re-importers.
No DDS Submission, But Only The Collection of An Information Set
Even downstream operators and traders benefit from several simplifications coming from both the Commission’s proposal and the Parliament amendments.
It is worth noting that these simplifications apply equally to all companies of this group, regardless of their size. This means that micro, small, medium and large downstream operators and traders will share the same requirements, although there are two small differences:
- The non-SMEs would still be required to register in TRACES.
- In case of suspicion that the products are not compliant, every company is expected to inform the competent authorities. But in case the situation raises ‘substantiated concerns’, only non-SME downstream operators and non-SME traders must also verify that the due diligence took place and that the DDS displayed a “no risk” or “negligible risk” result.
Apart from the case just described, the Commission completely cancelled the obligation for downstream operators and traders to verify the validity of the DDS numbers received from their suppliers, i.e., that previous due diligence had taken place.
It also deleted the requirement to submit a new DDS referencing all past DDS numbers collected from suppliers, and provided that they are no longer held liable in case of breach of the Regulation by companies upstream.
The Parliament specified that this group of companies no longer need to present the DDS number associated with the relevant products to the customs authorities in case of export from the EU market, which is rather a clarification than a new provision, given the fact that they do not have to submit any new DDS in general.
The only requirement remaining would be for them to collect and store a set of information about their Tier 1 suppliers and their customers, with the Parliament voting to exclude the reference and verification numbers from the list, except for the first downstream operator or trader.
The final list of the necessary information is therefore different and depends on the type of supplier. If the downstream operator or trader sources from a primary operator, the needed information is the following:
- the name, registered trade name or registered trade mark,
- the postal address,
- the email address and, if available, a web address.
- In addition, they must collect and store the reference numbers of the due diligence statements or the declaration identifiers associated with the relevant products from the primary operator.
Obviously, since they do not collect the DDS numbers anymore, they are also refrained from passing them along to the next business partners.
Instead, if the downstream operator or trader sources from another downstream operator or trader, the information to collect is limited:
- the name, registered trade name or registered trade mark,
- the postal address,
- the email address and, if available, a web address.
Still, all downstream operators and traders must collect the same limited information about the companies that then receive their products.
New Obligations For Competent Authorities
The implications for competent authorities after the Parliament vote at the end of November are lighter than for the rest of the stakeholders:
Competent authorities must refrain from issuing appropriate warnings and potential recommendations to operators before the application dates. This means that they cannot send any information notice before 30 December 2026 to large and medium companies, and before 30 June 2027 to micro and small enterprises.
On top of that, the communication about IT issues must be fostered between the Commission and the competent authorities. The latter should inform the Commission about any issues directly or indirectly generated by the IT system, while actively considering the IT-related pitfalls communicated by the Commission before the application date in order to avoid sanctions to operators impacted by such pitfalls.
Administrative Changes To Fast-Track The Decision & Ensure Support
The Parliament mandated that the Commission must create a standing stakeholder group and keep gathering practical input from experts and operators after the Regulation takes effect. This should help ensure that companies receive clearer guidance, especially in the initial months.
Parliament also endorsed skipping the standard eight-week review period normally granted to national Parliaments, in order to accelerate the legislative process.
Table 1: The Amendments And Their Impact
There were other amendments approved by the Parliament that aimed specifically at making the final text coherent. These were combined and integrated into the major amendments. You can find them listed in the table below. More info here: link.
The Remaining Open Points
The approved amendments changed the official text and introduced several changes. In the process of reviewing them, some open points emerged, and we have listed them below. These can offer some food for thought, especially regarding those aspects that remained ambiguous and that the Commission would need to address at the earliest opportunity to provide some clarification.
Point 1: The definition of “micro and small primary operators”
The definition of micro and small primary operators includes the following sentence: “Both operators based within and outside of the Union should be covered by the definition of micro and small primary operators”.
However, the definition of operators subject to the Regulation excludes by default companies based outside of the EU market. The Commission also stressed on previous occasions that the EUDR requirements apply only to EU companies, which makes the new definition quite confusing.
Point 2: The definition of “major changes” to the simplified declaration
The Parliament decided that the simplified declaration must be updated only in case of major changes. This can leave companies with doubts, because “major change” did not have a specific definition. In fact, how can a change be deemed “major” or even “minor”? On the other side, the simplified declaration has been stressed extensively as a one-time effort, leaving companies unsure of how to proceed.
Also, without the requirement to submit a DDS, re-importers will not have any DDS number to use in the customs declaration in the first place, which all creates legal uncertainty.
Point 3: What about the re-importers?
Downstream operators and traders no longer need to present the DDS number to the customs authorities in case of exports from the EU market. But what if they are re-importing those goods? Re-importers were defined as a typology of downstream operators in the latest FAQ document, so they should be included in this provision.
Point 4: The simplification review means new changes in 2026
The simplification review that the Commission will have to carry out before 30 April next year might bring additional modifications to the ever-changing Regulation. The immediate consequence of the simplification review would be for companies to freeze and remain in a legislative limbo with no clarity on what could come next.
Regarding those companies that have already invested in complying with the current deadline, a last-minute change would damage competitiveness and return on investment. These two are aspects that the EU has recently emphasised as fundamental for the European economy and success.
Moreover, based on ClientEarth’s analysis, taking a simplification review without an impact assessment could expose the Commission to the risk of breaching European law, according to which the measures must be strictly necessary to achieve their goals. Simplifying requirements without a new impact assessment, and before EUDR has been applied once, lacks justification.
What comes next?
The Parliament will vote on the final EUDR proposal on 16 December 2025. The EU institutions are currently working on a common agreement to present on that date. The vote should explore both the EUDR delay and the additional simplifications.
With the Parliament and the Council aligned, if not on the details, at least on the most substantive changes, the current expectations are that most of the amendments presented at the end of November might be approved.
However, the amendments approved by the Parliament are aligned with the Commission’s objectives, but take things too far. The Commission has strongly rejected the idea of a delay after the Council presented it in the middle of November and reminded that a missed agreement would result in applying the EUDR in its original version.
In addition, the Commission has publicly condemned the positions of the other two institutions and previously reminded that a missed agreement would result in applying the EUDR in its original version.
Still, this option might be difficult for the Commission to sponsor, as the EUDR delay was first proposed in its letter last September and justified by the unreadiness of the IT system. If anything has changed in the meantime, we cannot know at this stage.
All eyes are now on the next plenary session, which will decide the future of EUDR and, with it, the future of thousands of European and international businesses.
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