At the end of 2025, the EU Deforestation Regulation was not only postponed by one year, but also significantly changed in several key areas. With the timeline extended, preparation remains critical – especially for importers seeking clarity and guidance. This additional year is not a pause, but a valuable window to get ready.

New timeline:

• Large and medium-sized companies: EUDR applies from 30 December 2026
• Micro and small companies: EUDR applies from 30 June 2027

Due diligence obligations:

• Only primary operators and the first downstream operators have due diligence obligations à “primary operator + 1”
• Primary operators (first placing the product on the EU market) have the full responsibility to:
  • Prove that products are deforestation-free and legally produced
  • Upload a Due Diligence Statement (DDS) to the EUDR IT system
• First downstream operators must collect and store the DDS reference number but not check or verify the information in the DDS (unless there are substantiated concerns)
• After this step, due diligence obligations end. Further downstream operators have no EUDR duties

New category: micro and small primary operators

• If they operate from low-risk countries, they only need to submit a one-off, simplified declaration
• If the required information already exists in Member State databases, the Member states are required to create the DDS for the farmers. The system will automatically generate a reference number and forward to the farmers

Further simplifications may follow

• The European Commission must review the impact of these simplifications by 30 April 2026 and publish a report with potential additional simplifications.

Despite the simplifications, primary operators still carry the full due diligence obligation. They must prove that relevant products are deforestation-free and legally produced and submit the required Due Diligence Statement before placing products on the EU market. This is where Donau Soja and Crop Insights come in: We support you with an end-to-end software solution for EUDR compliance through Crop Insights, and tailored advisory services to help you prepare for and implement EUDR requirements.

If you want to navigate the EUDR with confidence, you can find more information here EUDR Info+Process – Donau Soja or get in touch with us at sustainability@donausoja.org