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EU Council Adopts Revised EUDR, Marking Final Step in Delay of Supply Chain Deforestation Law – ESG Today
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Environment/ Government
EU Council Adopts Revised EUDR, Marking Final Step in Delay of Supply Chain Deforestation Law
Mark Segal
December 19, 2025
Member states in the European Council announced on Thursday that they have formally adopted amendments to the EU Deforestation Regulation (EUDR), marking the last major legislative step to introduce a new 1 year delay and simplifications to the new law requiring companies to ensure that products imported to or exported from EU markets no longer contribute to deforestation and forest degradation globally.
The approval follows an agreement on revisions to the regulation between the Council and MEPs in the EU Parliament reached earlier this month to implement simplifications to the EUDR proposed by the European Commission, with the deal between lawmakers adding further simplifications and the new delay, and requiring the Commission to review the impact of the regulation early next year for potential additional simplification. MEPs in Parliament approved the revisions earlier this week.
The EUDR was introduced by the EU Commission in November 2021, and adopted in 2023, with the aim of effectively banning deforestation-linked products on the EU market, and establishing strong compliance requirements for companies providing or utilizing key commodities and products such as palm oil, beef, timber, coffee, cocoa, rubber and soy, in addition to some of their derived products, such as leather, chocolate, tires, or furniture.
The regulation set rules for companies that place relevant products on the EU market, or export them, introducing mandatory due diligence obligations, including a requirement to trace the products back to the plot of land where they were produced, to prove that the products were produced on land that was not subject to deforestation after 2020, and are compliant with all relevant applicable laws in force in the country of production.
The EUDR had initially been set to come into force at the end of 2024, but was delayed by a year at the request of the Commission to give companies more time to prepare for its compliance obligations. In September 2025, the Commission considered proposing a second one-year delay due to concerns regarding the ability of current IT systems to handle the data load created by the new regulation. In October, however, the Commission’s formal proposal retained plans to have the EUDR enter into force at the end of this year, but introduced a six-month enforcement grace period, and gave small enterprises until the end of 2026 to begin complying with the regulation.
In the process of developing their negotiating positions regarding the Commission’s proposals, however, both the EU Parliament and Council chose to push out the implementation of the new regulation by a year, with both legislative bodies agreeing to have the EUDR come into force at the end of 2026 for large companies, and in mid-2027 for smaller operators.
The Commission’s new proposal introduced a series of simplification measures into the EUDR regulation, shifting the focus of reporting obligations to the operators that actually place the relevant EUDR products on the market, while downstream operators such as retailers or manufacturers would no longer be obliged to submit due diligence statements, requiring only one submission, instead of multiple ones, in the EUDR IT system across the supply chain. For micro and small primary operators, the Commission’s new proposal reduced their obligation to submit only a simple, one-off declaration in the EUDR IT system, while if the information is already available, the operators would not have to take any action in the IT System themselves, replacing the previous need for regular submissions of due diligence statements.
The final agreement introduced additional simplifications to the EUDR, including placing the obligation to submit due diligence statements exclusively on the operators who first place the relevant products on the market, and having only the first downstream operator in the supply chain be responsible for collecting and retaining the reference number of the initial due diligence statement. The updated rules also ease compliance obligations for small and micro operators, requiring them to submit only a simple, one-off declaration in the EUDR IT system. The agreement also removes some printed products from the scope of the regulation, such as books, newspapers, and printed pictures from the scope of the regulation, due to their limited deforestation risk.
As part of the agreement reached between the Council and Parliament, the co-legislators also added a requirement for the Commission to carry out a new simplification review of the EUDR by the end of April 2026 – even before the newly proposed implementation dates – to evaluate the administrative burden and impact of the regulation, which could open the EUDR to even further changes.
With the adoption by both Council and Parliament complete, the update EUDR will now be entered into the Official Journal of the European Union and will enter into force three days after publication.
Mark founded ESG Today following a 20 year career in investment management and research. Prior to founding ESG Today, Mark worked at Delaney Capital Management (DCM) in Toronto, Canada, most recently as the firm’s head of U.S. equities. While at DCM, Mark was part of the firm’s ESG team, responsible for evaluating and tracking the sustainability factors impacting portfolio companies, and assessing the suitability of companies for portfolio inclusion. Mark also spent several years in the sell-side research industry, covering the technology and services sectors. Mark holds an MBA from Columbia University in New York, a BBA from the Schulich School of Business at York University in Toronto, and is a CFA charterholder.
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