The EU Deforestation Regulation (EUDR), which entered into force on 29 June 2023, represents a key step in the European Union's efforts to combat global deforestation. Its main objective is to ensure that products placed on or exported from the EU market did not contribute to deforestation or forest degradation.

The EUDR was originally expected to enter into force on 30 December 2024. However, due to concerns that affected companies and stakeholders had not had sufficient time to prepare, the implementation was postponed by a year. As a result, The rules will apply to medium and large operators and traders on 30 December 2025., while they will be extended to micro and small enterprises on 30 June 2026.

Latest developments and guidelines

The European Commission is actively working to clarify and simplify the EUDR requirements. On 15 April 2025, the Commission published updated guidelines along with updated FAQs (fourth version)In addition, on 20 May 2025, the Commission adopted implementing regulation under the EUDRwhich classifies countries by deforestation risk in the production of seven key commodities: cattle, cocoa, coffee, palm oil, rubber, soy and timber.

This benchmarking system is intended to serve as a guide for companies to conduct due diligence depending on the country of origin of their products. Interestingly, only four countries are designated as high-risk (Myanmar, Russia, North Korea and Belarus). The Commission's rationale for classifying most countries as low-risk is to focus collective efforts and resources on forest protection in areas with more acute deforestation problems, which also reduces costs for operators.

The updated documents are the result of feedback from Member States and aim to simplify and clarify the measures and procedures under the EUDR. The Commission expects that this simplification will help to achieve harmonised application and enforcement of EUDR across the EU and will lead to a 30% reduction in administrative costs and burdens for companies.

Key simplification measures include:

• Reusability of Due Diligence Statements (DDS) for non-SME companies, if the products in question were already on the EU market.
• Company authorization submit DDS annually, instead of for each shipment, while one DDS can cover multiple physical shipments, provided that due diligence has been performed and the shipments are not older than one year.
• An authorized representative may file DDS on behalf of members of a group of companies, however Due diligence obligations apply to individual companies, not in groups.
• Clarification on how due diligence is demonstrated, leading to simplified obligations for non-SMEs in the supply chain.
• The first report from non-SME operators will have to be submitted only after 30 December 2026.

Persistent concerns and calls for further simplification

Despite the Commission's efforts at simplification, significant concerns remain. In July 2025, a coalition of 17 European organisations from the agricultural, forestry, livestock, trade and processing sectors issued a joint statement calling for further simplification of the EUDR and highlighted the need for more targeted, risk-based and practical implementation. These groups argue that the current framework is impractical and may divert commodity flows, while the guidelines are not legally binding and may be interpreted differently in member states.

Similarly 18 EU agriculture ministers called for the simplification of the EUDR, arguing that the regulation does not take into account existing forest protection laws in many low-risk Member States and instead targets deforestation where the risk is highest, imposes disproportionate bureaucratic obligations.

On 9 July 2025, the European Parliament approved a proposal calling for repeal of the implementing regulation due to alleged shortcomings in the methodology for comparing countries. Although the EP vote is non-binding, it puts pressure on the Commission to revise the EUDR and add a ‘zero risk’ (or negligible risk) category. However, such a change could pose a risk, for example, that an ingredient or product linked to illegal deforestation could more easily enter the EU via a ‘zero risk’ country.

The future of EUDR

The EUDR is expected to be part of the latest EU Omnibus Simplification Package, which is due to be published in autumn 2025. This initiative will review existing environmental legislation under the EU Green Deal and adapt it to new developments. It is worth noting that the application of other related legislation, such as the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDD), has also been postponed.

Overall, the implementation of the EUDR is a dynamic process, where environmental protection efforts meet practical implementation challenges and simplification demands from industry and Member States. JRi