European Commission Maintains 30 December 2025 Application Date for EU Deforestation Regulation

On 21 October 2025, the European Commission (Commission) announced a proposal introducing amendments designed to facilitate the implementation of the EU Deforestation Regulation (EUDR). Notably, the Commission proposed to maintain the current application date of 30 December 2025 for large- and medium-sized enterprises, contrary to a recent announcement of the intention to delay the EUDR’s application by another year.

The Commission also proposed amendments that focus on streamlining compliance obligations, particularly for micro and small operators, while maintaining traceability and enforcement standards to address deforestation associated with products placed on the EU market.

Background to the EUDR and Previous Guidance Measures

The EUDR requires operators and traders placing covered commodities or products on the EU market, or exporting them, to conduct due diligence showing that the goods are deforestation‑free and produced in line with the laws of the country of production. The EUDR covers cattle, cocoa, coffee, palm oil, rubber, soy, and wood, in addition to a wide range of products derived from those commodities.

The Commission has sought to simplify and clarify aspects of the EUDR implementation through the publication of guidance documents and FAQs. The Commission also introduced the Benchmarking Implementing Regulation in May 2025, which classifies countries of sourcing of commodities into risk categories (high, standard, or low). For more detail, see this Latham article.

Proposed Amendments to the EUDR

The Commission’s proposal responds to stakeholder feedback and seeks to reduce administrative burdens through several simplification measures, including:

• Simplified reporting for downstream operators: Operators and traders “commercialising” (i.e., selling downstream) EUDR-relevant products after the initial placement on the EU market of the product or all of the relevant products or commodities that the product is made from will no longer be required to submit due diligence statements. Hence, responsibility for due diligence and reporting will rest primarily with the upstream operator introducing the product or commodity to the EU market.
• One-off declarations for micro and small operators: Micro and small primary operators from low-risk countries, including (according to the Commission) nearly all EU farmers and foresters, will be required to submit a simple, one-off declaration in the EUDR Information System. Where relevant information is already available in Member State databases, no further action will be required from these operators.

These measures come amid the Commission’s aim for simplification of EU sustainability and environmental rules.

Revised Implementation Timeline

The EUDR’s application date has already been postponed by one year, from 30 December 2024 to 30 December 2025 (see this Latham article). More recently, on 2 October 2025, the Commission announced that it would introduce a proposal for a further one-year delay, which would have shifted the application date for most operators and traders to 30 December 2026, in light of concerns regarding the EUDR Information System (see this Latham article).

However, the Commission has now instead proposed a phased implementation schedule with transitional periods. Large and medium enterprises will continue to be subject to the EUDR from 30 December 2025 (rather than the proposed postponed date of 30 December 2026), but there will be a six-month grace period for checks and enforcement. Micro and small enterprises will have until 30 December 2026 to comply (instead of 30 June 2026 under the currently enacted law). According to the Commission, these transitional periods are designed to ensure that the EUDR Information System can accommodate the anticipated volume of due diligence statements and provide companies with sufficient time to adapt.

Next Steps

The proposal will be considered by the European Parliament and the Council, which must formally adopt the targeted amendments before they take effect and can propose further amendments. The Commission has called for adoption of the proposal by 30 December 2025.

For an overview of the broader EU state of play regarding circularity and product-related frameworks, including the EUDR, see this Latham article.

Latham & Watkins will continue to monitor developments relating to ESG regulatory updates in the EU and globally.

This article was prepared with the assistance of Samantha Banfield at Latham & Watkins.