Who is affected?
The EUDR will continue to apply to sellers and medium-sized and large market participants from 30 December 2025. These companies must prepare to comply with the extensive due diligence and documentation requirements from the date of application. For market participants that are considered micro and small enterprises, however, a postponement is planned – they must comply with the requirements from 30 December 2026.
New roles and different obligations
The draft amendment now distinguishes between the roles of "micro and small primary operators", "economic operators", "downstream operators" and "traders". The introduction of new roles leads to both new obligations and an adjustment of existing roles and their duties.
Transitional periods and regulatory controls
For medium-sized and large companies, a six-month transition period is to apply from 30 December 2025, during which the authorities are required to issue only warnings and recommendations, instead of sanctions. This is intended to give companies the opportunity to adapt their processes to the new requirements without having to fear possible sanctions.
What needs to be done now?
All companies covered by the EUDR should now use the remaining time to review their supply chains, optimise and implement their due diligence processes, and familiarise themselves with the new potential roles and obligations. The Commission recommends registering early on the TRACES portal and consulting the relevant guidelines and FAQ documents.
What happens next?
The draft amendment to the EUDR is now to be discussed in the European Parliament and Council. The European Council already published a counterproposal on 19 November. Initial votes are expected to take place in the European Parliament this week. In order for the amendments to enter into force before the current date of application on 30 December 2025, agreement must be reached in the trilogue procedure and publication in the Official Journal must take place.
Are you aware of your obligations under the draft amendment to the EUDR?
Arrange a personal consultation with our EUDR experts now! We will work with you to analyse the proposed amendments and clarify any open questions: The trade-e-bility consulting team will be happy to assist you via +49/40/750687-300 or send us an email.
