EUDR update: Council proposes pragmatic approach to postpone and simplify the application
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Partner
Netherlands
I am a partner in our NL office, based in The Hague, where I was one of its founding lawyers in 2001.
Partner
Belgium
As a partner in our Regulatory & Administrative practice in Brussels, I provide strategic advice and practical support to international, EU, and Belgian companies, industry associations, and other clients navigating EU regulatory law, market access, compliance, consumer protection, and sustainability regulations including ESG frameworks, green claims, deforestation-free, and ecodesign requirements.
Associate
Netherlands
As an associate in our Regulatory and Competition & EU Law team in The Hague, I advise on a wide range of regulatory matters and EU law, with an emphasis on sustainability, including ESG, Energy, and Environmental Law.
On 19 November 2025, the Council of the European Union adopted its negotiating mandate for a targeted revision of the EU Deforestation Regulation (EUDR), signaling a more practical path forward for businesses and member states.
The Council's mandate includes the following key developments:
Extended timeline
Application postponed by another year to 30 December 2026 for medium and large operators, with an additional six-month buffer until 30 June 2027 for micro and small businesses;
Simplified compliance
The obligation and responsibility for submitting due diligence statements should fall exclusively on operators who first place products on the market, eliminating duplicate reporting requirements for downstream operators;
No due diligence statements obligations downstream
Only the first downstream operators must submit due diligence statements, and pass on the reference number of the initial statement to downstream operators and traders;
Reduced burden for micro and small companies
Micro and small primary operators will submit just a one-off simplified declaration.
With this mandate, the Council refuses the Commission's proposed "grace period" in favor of clear, uniform application dates. Downstream operators will simply need to maintain and pass on reference numbers rather than submit separate statements.
Importantly, the Commission will be tasked with conducting a comprehensive simplification review by 30 April 2026 to assess the regulation's impact on operators, particularly smaller businesses, with potential legislative proposals to follow.
Next: Negotiations with the European Parliament will now begin, with the aim of reaching final agreement in the coming weeks.
This revision demonstrates the EU's commitment to balancing environmental ambition with practical implementation – a necessary recalibration as businesses and authorities prepare for this landmark sustainability regulation.
Of course, the question remains whether the proposed revisions are compatible with the EU treaties, general principles of EU law, and international law on State climate obligations.
If you are interested in EUDR updates or have any questions about the application of the EUDR, please feel free to contact any of the authors.
