Dec 1, 2025
EUDR Update: Parliament Proposes 12 Month Delay, Additional Simplifications as EUDR Enters Trilogue Negotiations
During last week's plenary session, EU Parliament adopted their official position on EUDR, voting in line with the proposal to delay introduced by the EU Council the previous week. This means that both the Council and the Parliament are in support of maintaining the core elements of the simplification proposal introduced by the Commission, with an additional 12-month delay to December 30th 2026. Parliament’s proposal, however, does introduce some notable changes compared to the Council’s and Commission's.
Here is an overview of what each body is proposing, and what we can expect as the EU heads into trilogue negotiations.
EU Parliament supports 12 month delay, modifications to Annex I, and additional simplification measures
For Large Operators:
Entry into application to be delayed to December 30, 2026
For Micro and Small Primary Operators:
Entry into application is postponed to June 30, 2027, with additional time for micro and small primary operators placing timber on the market
Exemption from due diligence statement requirements (only a one-time simplified declaration needed)
Simplified Due Diligence Obligations for Downstream Operators and Traders:
Traders and downstream operators will no longer need to submit due diligence statements. The Parliament proposal also removes the obligation for downstream operators and traders to communicate any reference numbers to their clients. Moreover, the obligation to collect and keep reference numbers should only apply to the first downstream operator and should not apply to all others further downstream in the supply chain.
Modification of the Scope of the Regulation:
Parliament proposes a modification to Annex I of the regulation, i.e. the list of products in scope, to remove printed books, newspapers, pictures and other products of the printing industry, manuscripts, typescripts and plans of paper.
Review Clause
Finally, the Regulation must undergo a review in April 2026, introducing the possibility of further simplification provided such simplification receives legislative approval.
EU Council supports 12 month delay, slight modifications to simplified due diligence obligations compared to Commission's proposal
For Large Operators:
Entry into application to be delayed to December 30, 2026
For Micro and Small Primary Operators:
Entry into application is postponed to June 30, 2027
Exemption from due diligence statement requirements (only a one-time simplified declaration needed)
Simplified Due Diligence Obligations for Downstream Operators and Traders:
Traders and downstream operators will no longer need to submit due diligence statements. The Council's proposal also only requires the first downstream operator to keep and pass on reference numbers.
Review Clause
The Regulation must undergo a review in April 2026.
EU Commission proposes December 30, 2025 application date with 6 month grace period
For Large Operators:
Entry into application to remain December 30, 2025.
6 month grace period during which no enforcement will be conducted by competent authorities. If non-compliance is found, authorities may only issue warnings to operators.
For Micro and Small Primary Operators:
Entry into application is postponed to December 30, 2026.
Exemption from due diligence statement requirements (only a one-time simplified declaration needed)
Simplified Due Diligence Obligations for Downstream Operators and Traders:
Traders and downstream operators will no longer need to submit due diligence statements. All traders and downstream operators are responsible for collecting and maintaining due diligence reference numbers within their own systems, and sharing them with their clients further downstream.
Next steps: EU enters into trilogue negotiations; compromise must be reached by December 15th plenary
While the EU Parliament and the Council's proposals both support a 12-month delay, all three proposals are slightly different. Trilogue negotiations must result in an agreement reached before the December 15-18 plenary session (the final plenary session of the year).
Meanwhile, companies should continue to prepare for EUDR compliance to ensure they are ready no matter the outcome of trilogue negotiations. To learn more about how Sourcemap can help your organization prepare for what's coming, reach out to our team of experts.
