EUDR Update: Provisional Agreement Reached on December 2026 Application Date, Additional Simplification

On December 4th, a provisional agreement was reached during trilogue negotiations on the EU Deforestation Regulation. Here's what you need to know.

1 year delay confirmed: December 2026 application date for large and medium primary operators

The provisional agreement delays the application date of the Regulation to December 2026 for large and medium primary operators, with an additional 6 months for micro and small primary operators. This comes on the heels of both Parliament and the Council advocating for a one year delay of the Regulation in their respective proposals.

Modification of Annex I

Per Parliament's proposal, the provisional agreement will modify Annex I of the Regulation to exclude "printed books, newspapers, pictures and other products of the printing industry, manuscripts, typescripts and plans of paper." This effectively excludes the printing industry and its associated HS codes from the scope of the Regulation.

Simplified due diligence obligations

The obligation and responsibility to submit due diligence statements will fall exclusively on the primary operators who first place products on the market. This can either be an operator importing a good into the EU, or exporting a good from the EU if that good was grown and manufactured within the EU and said export represents the first time the good is placed on the market. Downstream operators and traders will no longer have any obligation to submit due diligence statements to EU Traces.

Furthermore, under this provisional agreement only the first downstream operator will be responsible for collecting and retaining the due diligence reference number of the initial due diligence statement(s) and maintaining it within their systems, rather than passing that reference number further downstream. Any downstream operators and traders further down the supply chain have no further responsibilities.

Opportunity for further review in April 2026

The EU Commission must present a report by April 30, 2026 reviewing the Regulation and, if appropriate, may present a new legislative proposal to further simplify obligations. Said proposal must undergo a legislative approval process in order to be adopted into law.

What comes next?

The provisional agreement will now be endorsed and formally adopted by both institutions before entering into force, replacing the current adopted text. On the EP side, the plenary vote is already scheduled for December 16, 2025.

After an eventful fall and winter of EUDR uncertainty, the Regulation is still set to go into effect in December 2026, and due diligence obligations for primary operators currently remain unchanged.

To learn more about your EUDR exposure and how these updates may impact your business, reach out to Sourcemap's team of experts today.