After the European Commission published a proposal in September to postpone the start of the EU Deforestation Regulation (EUDR) by one year for all companies, a new and different proposal has now been released.  

Revised scope and simplified obligations
Under this new version, the postponement would apply only to micro and small enterprises, while medium and large companies would still have to start applying the EUDR requirements from 30 Dec 2025. However, for these larger companies, the Commission proposes a six-month grace period, during which no checks or penalties would be carried out. 

The proposal also introduces simplifications for all downstream companies. According to the new draft, only the first placer on the market will have to conduct due diligence and upload a Due Diligence Statement (DDS) to the EUDR information system. 

All downstream companies along the supply chain would then only need to collect and pass on the DDS reference number for ensuring traceability of products, without having to ascertain due diligence was carried out. 

A new category, called “Micro & Small Primary Operators”, would also be introduced, which would cover EU farmers, among other operators. This category applies to: 

• a natural person or micro-/small-sized undertaking in a low-risk country, 

• producing the relevant commodities themselves. 

These operators would not need to submit a regular DDS but instead file a one-time simplified declaration in the EUDR information system, where geolocation data could be replaced by the postal address.

Next steps and implications for companies
It is important to stress that this is only a proposal by the European Commission. It must still be adopted by the European Parliament and the Council before 30 Dec 2025 to enter into force. The currently valid version of the EUDR still requires medium and large companies to comply from 30 Dec 2025, without any grace period or simplifications. 

The introduction of a “zero-risk category” is not yet part of the proposal, although there is strong political pressure from various stakeholders to include it. The outcome of the ongoing negotiations between the EU co-legislators remains uncertain. 

Given this uncertainty, companies are strongly advised to continue preparing together with Donau Soja and Crop Insights, ensuring they are ready regardless of which version of the EUDR will ultimately apply. And beyond legal compliance, companies are still committed to demonstrate deforestation-free supply chains and CO₂ reductions – goals that Donau Soja and Crop Insights help companies verify and achieve.