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In brief

On 4 December 2025, the European Parliament and Council reached a provisional political agreement to postpone the application of the EU Deforestation Regulation (EUDR) by one year for all businesses. The agreement also introduces targeted simplifications to due diligence requirements.


Key takeaways

Delay to application timeframe

The provisional agreement removes the six month “grace period” initially proposed by the Commission for large and medium companies. All businesses will have one more year to comply with the EUDR as follows:

  • Large and medium operators and traders: the EUDR will apply from 30 December 2026.
  • Micro and small operators: the EUDR will apply from 30 June 2027.

Simplification of due diligence obligations

Under the provisional agreement, responsibility for submitting a due diligence statement (DDS) is limited to operators first placing a relevant product on the EU market, meaning that there will be no requirement for downstream operators or traders to submit a DDS. Additionally, the obligation for all operators and traders to pass DDS reference numbers down the supply chain, as set out in the Commission’s initial simplification proposals, has been removed such that only the first downstream operator in the supply chain must collect and retain the reference number of the initial DDS.

In keeping with the Commission’s proposals, the provisional agreement also provides that micro and small primary operators will only have to submit a one-off simplified declaration in the EUDR IT system, replacing the previous requirement for DDS submissions for these entities.

Review of the EUDR

The European Commission has been tasked by both co-legislators with conducting a simplification review and presenting a report by 30 April 2026 to assess the administrative burden of the EUDR, particularly for smaller operators. The report should indicate ways to address the identified issues, including through guidelines and improvements to the information system and, where appropriate, be accompanied by a legislative proposal.

Amendments to scope

Under the provisional agreement, certain printed products (such as books, newspapers and printed materials) have been removed from the EUDR scope. The Council has confirmed that this reflects the limited deforestation risk associated with these items.

Next steps

The European Parliament and the Council must formally adopt the provisional agreement before it can come into effect. It is expected that the European Parliament will vote on the deal during its 15-18 December 2025 plenary session. The agreed text must then be published in the EU’s Official Journal before the end of 2025 for the changes to enter into force.

For more information, please contact our team of experts.

Author

Graham Stuart is a partner in Baker McKenzie's London office specialising in product regulation and environmental, health and safety law.

Author

Eva-Maria is a partner in our Austrian corporate / M&A group and a member of our global sustainability practice. She acts as global lead sustainability partner for our financial institutions industry group, heads Baker McKenzie's capital markets practice in Austria and is a member of our EMEA steering committee for capital markets. Eva-Maria is a dual-qualified lawyer, admitted to practice in Austria and New York. Prior to joining Baker McKenzie's Vienna office in 2008, Eva-Maria worked in the New York, Paris and Frankfurt offices of a well-known US law firm.

Author

Bibi is a junior associate at the Firm’s London office. She completed her degrees in Biology and Environmental Technology from Imperial College London, followed by a Graduate Diploma in Law and Legal Practice Course (LLM) from BPP University. Bibi joined Baker McKenzie as a trainee in 2023 and qualified in 2025.

Author

Gabrielle is a Senior Associate in the London office with over 15 years of experience (in the UK, EU and Brazil) supporting global businesses and non-profit organisations with legal, strategy, disputes, risk management and governance advice, in particular for tax and ESG matters.